Mexico: New requirements for documentation
Mexico has introduced transfer pricing documentation requirements for a master file and local file in line with the OECD Base Erosion and Profit Shifting (BEPS) project from 1 January 2016. It will be mandatory to prepare this information for
See MoreHungary: Tax amendments approved by parliament
The parliament of Hungary approved a bill on 17 November 2015 establishing some additional amendments to the country's current tax system. According to the approved bill a classification system will be introduced and companies will be classified as
See MoreAustralian Senate passes Government’s multinational anti tax avoidance measures
The Turnbull Government has secured the passage of the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill, a critical piece of legislation, which will ensure major international companies operating in Australia but booking profits
See MoreTransfer Pricing Brief: November 2015
Greece: Documentation requirement: Transfer pricing documentation requirements as set out by the Income Tax Code and the Procedural Code do not apply in respect of transactions made by real estate investment companies as per the clarification
See MoreFrance adopts country-by-country reporting requirement
The lower house of the parliament in France adopted an amendment to the Finance Bill for 2016 on 12 November 2015. The amended Finance Bill introduces a country-by-country reporting requirement for multinational companies which will be applicable
See MoreUK: Autumn Statement Includes Measures Effective from 25 November 2015
The Chancellor of the Exchequer delivered his Autumn Statement to Parliament on 25 November 2015. The measures with immediate effect from 25 November 2015 are as follows: Loans to participators, trustees of charitable trusts: This measure affects
See MoreCzech Republic: Ministry of Finance holds conference on countering tax evasion
The Finance Ministry held a conference on 18th November 2015 regarding tax evasion and measures taken to counter it. It was reported that because of intensifying the fight against tax evasion and avoidance, public revenues had increased. In
See MoreNetherlands: Lower House of the Parliament Adopted the Tax Plan 2016
The lower house of the parliament adopted the Tax Plan 2016 on 18 November 2015. The same was presented to the lower house of the parliament on 15 September 2015 by the Minister of Finance. The important measures were included on corporate tax and
See MoreNigeria: Implications of BEPS proposals
The Federal Inland Revenue Service (FIRS) has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing
See MoreIreland’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
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