Ireland’s Revenue published the Manual on role of the competent authority
On 9 November 2015, the Irish Revenue issued a manual regarding the role of the Irish competent authority in resolving international tax disputes and ensuring the correct allocation of taxable profits to Ireland. Mutual agreement procedures
See MoreIndia: No Transfer pricing adjustment when tax avoidance not possible
The Mumbai Bench of the Income-tax Appellate Tribunal in the case of: DCIT v. Tata Consultancy Services Ltd. (ITA no. 7513/2010), held that an Assessing Officer cannot “mechanically” refer a taxpayer’s international transaction to a Transfer
See MoreTransfer Pricing Brief: October 2015
UK: CbC reporting requirement: UK has published draft Regulations in relation to Country by Country (CbC) reporting, along the lines of the recommendations made in the OECD action plan on base erosion and profit shifting (BEPS). The Regulations
See MoreMexico: Lower Chamber approves tax reform for 2016
Mexico’s President submitted to Congress tax reform for 2016 on 8 September 2015 was approved by the Lower Chamber with certain adjustments, on 29 October 2015. As per the tax reform proposal which is expected to be signed by the President to
See MoreUS: Issues Notice Requesting Comments on Transfer Pricing Penalties
The US Internal Revenue Service (IRS) and the Treasury Department have issued a notice requesting comments on transfer pricing penalties as per temporary and the final regulations. Under both the temporary and the final regulations the penalty may
See MoreIndia Publishes Notification on Use of Arm’s Length Range and Multiple Year Data
Recently, the Central Board of Direct Taxes published 'Notification No. 83/2015' of 19 October 2015 revising the Income-tax Rules, 1962 in relation to the use of range and multiple year data. The Notification amends Rule 10B and introduces Rule
See MoreGreece: Public Revenue Authority Published Clarification on Transactions of Real Estate Companies and Comparables
Public Revenue Authority of Greece published clarification on transactions of real estate companies and comparables data. The Public Revenue Authority issued document ΔΕΑΦΒ 1136663 ΕΞ 2015/21.10.2015 to clarify that the transfer pricing
See MorePoland: The President of Republic amends rules on transfer pricing documentation
The President of Republic of Poland signed an Act amending the Corporate Income Tax (CIT) Act, the Personal Income Tax (PIT) Act on 27 October 2015. The Act initiated important changes related to transfer pricing (TP) documentation. As per the
See MoreGreece: Enacted Rules on Transfer Pricing Penalties and Issued Guidance on TP Documentation
Greece enacted changes to the applicable transfer pricing (TP) documentation rules based on Law 4337/17.10.2015 on 17 October 2015 and issues guidance. Based on the new Law 4337/17.10.2015, the following changes are introduced to the penalties
See MoreHungary: Draft bill for tax law changes in 2016
The government of Hungary recently presented to the Parliament a draft bill with proposals for tax law changes which would take effect as from 2016. The proposed draft bill creates a classification system for taxpayers based on the level of risk
See MoreDenmark: Government publishes a proposal to introduce CbC reporting
The Danish government published a proposal on 18 September 2015 to amend the current tax law, and provide measures that would increase the Danish transfer pricing documentation requirements and include country-by-country (CbC) reporting. The
See MoreIreland: Budget 2016 announced
On 13 October 2015, the Finance Minister of Ireland announced Budget proposals for 2016 in the context of the country being the fastest growing economy in Europe for 2015, with GDP growth at 6.2%. The Minister also published a document
See MoreUK: Consultation on draft Regulations on country by country reporting
On 5 October 2015 the UK issued draft Regulations in relation to country by country reporting, along the lines of the recommendations made in the OECD action plan on base erosion and profit shifting (BEPS). The aim is to require multinational groups
See MoreTransfer Pricing Brief: September 2015
Ukraine: Comparable uncontrolled price method (“CUP”): As per the new law which came into force from August 11 2015, taxpayers are allowed to use Comparable Uncontrolled Price (“CUP”) method only with reference to the prices on the
See MoreSpain: Partial amendments of general tax law
Spain has published the official Gazette regarding partial amendments of general tax law which was amended on 22 September, 2015 as a Law no.34/2015. The Law will enter into force on 12 October 2015 except for the obligation to keep specific
See MoreNew Zealand: Inland Revenue revises its guidance on APA
Inland Revenue recently updated its guidance on the Advance Pricing Agreement (APA) application process and published a list of steps aiming to standardize the process. Agreements can be required from Inland Revenue alone (unilateral) or between
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See MoreColombia: National Tax Authority Issued Transfer Pricing Rules on Sales of Intangibles
The National Tax Authority of Colombia announced on sale transactions of intangibles subject to the transfer pricing regime. In article 260-1 of the Tax Code provides criteria for ascertaining whether two or more parties are related parties and the
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