Canada: Proposal regarding CbC reporting in Budget 2016
Canadian Budget for 2016 proposes new legislation to strengthen transfer pricing documentation by introducing country-by-country reporting for large MNEs. The new transfer pricing documentation rules will follow the base erosion and profit shifting
See MoreTurkey: Draft communiqué on transfer pricing documentation, country-by-country reporting
The revenue administration of Turkey has issued a draft communiqué on 16th March 2016 that would introduce new transfer pricing documentation rules that generally follow the base erosion and profit shifting (BEPS) Action 13 recommendations and
See MoreIndia: Country-by-country reporting, transfer pricing documentation rules in budget 2016
The fiscal budget was announced in India on 29 February 2016. One of the most important developments from a Transfer Pricing (TP) regulations perspective was introduction of Country-by-Country (CbC) reporting norms for TP documentation. If this
See MoreIndia: Marketing & Sales Promotion Expenses Not International Transactions for Arm’s Length Standard
The Bangalore Bench of the Income-tax Appellate Tribunal held in the case of: Essilor India vt. Ltd. v. DCIT that advertising, marketing, and sales promotion expenses to promote brand value were incurred only for increasing the taxpayer’s sales,
See MoreEU Joint Transfer Pricing Forum Discusses Comparables in the EU
The meeting of the EU Joint Transfer Pricing Forum (EU JTPF) on 18 February 2016 considered some of the relevant issues concerning transfer pricing including joint audits in the EU and the use of pan-European comparables. Joint audits in the EU A
See MoreUK: Introduced Country-by-Country (CbC) Reporting Requirement as Final Regulation
UK has introduced Country-by-Country (CbC) reporting requirement for domestic entities with consolidated group revenue of €750 million or more for an accounting period. The Commissioners may give a general or specific direction to a reporting
See MoreUS: Transfer Pricing Adjustments for Consolidated Group Members
The U.S. Tax Court has issued an opinion concluding that the IRS Commissioner—in exercising authority under Code section 482 and adjusting the reported prices for items transferred among taxpayers and their foreign affiliates—is not required to
See MoreTransfer Pricing Brief: February 2016
Taiwan: Transfer Pricing Rules: As per the amendments to the Regulations governing assessment of profit-seeking enterprises, it is mandatory to apply the arm's length principle in the attribution of profits in a business restructuring provided
See MoreIndia: CBDT issues guidance on transfer pricing audit procedures
The Central Board of Direct Taxes (CBDT) in India has issued Instruction No. 3 of 2016 on 10 March 2016, with immediate effect as new guidance to provide guidance to Assessing Officers (AOs) in selecting cases for transfer pricing (TP) audits in
See MoreChile: IRS established an obligation to submit a new affidavit aligned with BEPS
According to tax audit strategy of Chile, the Internal Revenue Service (IRS) has improved its formal requirements for Chilean taxpayers. On 24th December 2015, the IRS established an obligation to submit an affidavit F.1913 (Annual Return of Global
See MoreUK: HMRC Clarifies Approach to Taxing Multinationals
The UK Parliament’s Public Accounts Committee is taking evidence on 11 February 2016 in relation to the tax affairs of multinational enterprises. In advance of the parliamentary hearing the UK tax authority HMRC has published a factsheet on its
See MoreRomania: New rules enacted for transfer pricing documentation
As per the Order no. 442/2016 published by the National Agency for Fiscal Administration (ANAF) on February 2, 2016, “large taxpayers” engaged in transactions with related parties, having a total annual value determined by reference to the value
See MoreEU Joint Transfer Pricing Forum meeting in February 2016
The next meeting of the EU Joint Transfer Pricing Forum (EU JTPF) is scheduled for 18 February 2016. The EU JTPF aims to provide tools for practical application of transfer pricing rules in the EU and ensure efficient transfer pricing
See MoreTransfer Pricing Brief: January 2016
Norway: Base Erosion and Profit Shifting (BEPS) Related Compliance: General Rule for Country by Country (CbC) Reporting: The Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. As per
See MoreNigeria: Country-by-country reporting update
A Multilateral Competent Authority Agreement (MCAA) has been signed by Nigeria for executing the exchange of country-by-country (CbC) reports. This reports will include summary of income earned and tax paid, and the number of employees positioned by
See MoreRomania: Government publishes new Orders on tax rulings and APAs
The Romanian Government published Orders at the end of 2015 regarding binding tax rulings and advance pricing agreement (APAs). Under the provisions on binding tax rulings the tax situation that is to be the subject of the ruling must be in the
See MoreFrance-New country-by-country reporting requirement, transfer pricing declaration
The Finance Act for 2016 and the Amended Finance Act for 2015 were published in the official journal on 30 December 2015. The Finance Act for 2016 introduces a country-by-country reporting obligation in Article 223 C of the French general tax code,
See MoreFinland: Ministry of Finance publishes a proposal regarding transfer pricing documentation rules and CbC reporting requirements
The Ministry of Finance on 21 December 2015 released for public comment a proposal to revise the transfer pricing documentation rules and introduce country-by-country (CbC) reporting. The proposed legislation would follow the three-tiered approach
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