Australia: Profit shifting through the artificial loading of debt
Two key issues have emerged for taxpayers, with the arrival of an Australian Treasury Paper, addressing profit shifting through the artificial loading of debt in Australia. Effective from 1 July 2014, the safe harbour for debt has been diminished
See MorePoland: Transfer pricing for business restructurings
Poland’s Finance Ministry issued decrees that bring the transfer pricing provisions of Poland’s tax law into line with international transfer pricing standards on September 3, 2013 and the decree effective from 18 July 2013. The decrees
See MoreAustralia: Prepare for an Australian Taxation Office (ATO) review
Australia is increasingly giving attention to transfer pricing issues and has recently introduced changes in the law to align the transfer pricing rules more closely to the OECD Guidelines. Taxpayers need to be completely ready for an Australian
See MoreMexican Tax Authority increases focus on auditing supply chain structures
Recent developments within the Mexican Tax Administration Services (SAT) demonstrate an increased focus on auditing supply chain restructurings. This is in line with international trends in transfer pricing, for example the report on business
See MoreTransfer Pricing Brief: August 2013
Indonesia Certain small and medium enterprises may be taxed on the basis of 1% of turnover. Israel Lower rates apply to companies eligible under the Law for the Encouragement of Capital Investment. Malaysia A Transfer Pricing Audit Framework
See MoreAustralia: Effective date of new Transfer Pricing rules
The new transfer pricing rules introduced by Australia are effective for years starting on or after 1st July 2013 and will apply to the transactions of all multinational entities operating in Australia. Before documenting their assessment forms,
See MoreIndia – CBDT Releases Drafts on Transfer Pricing Safe Harbor Rules
India’s Central Board of Direct Taxes (CBDT) released draft transfer pricing “safe harbor” rules as part of an initiative by the government to reduce the number of transfer pricing audits and protracted disputes on 14th August 2013,. Under the
See MoreIndia – No transfer pricing adjustment required on certain interest-free advances
Recently, Income Tax Appellate Tribunal by a ruling rejected and deleted transfer pricing adjustments proposed with respect to a taxpayer’s interest-free advances made to its related party (a U.S. subsidiary) on a finding that the taxpayer had
See MoreUkraine: New transfer pricing rules
A law “On the Amendments to the Tax Code of Ukraine Regarding Transfer Pricing” passed its second and final reading on 4 July 2013 and was adopted by the Ukrainian Parliament. This legislation will become effective from 1 September
See MoreRussia- Clarification on documentation to verify appropriate transfer pricing method
The Ministry of Finance of Russia has issued public letter No. 03-01-18/26965 in relation to transfer pricing documentation on July 11, 2013 that clarifies process for preparing and submitting transfer pricing documentation for a particular
See MoreIndia: Criteria for manual selection of cases for transfer pricing audit
Instruction No. 10 of 2013 has been issued by the Central Board of Direct Taxes (“CBDT”) on 5th August 2013 which specifying the procedures and criteria for manual selection of cases by the tax administration for audit/ scrutiny for financial
See MoreHungary: amendment to transfer pricing documentation rules
The Ministry of Finance of Hungary issued an amendment of Decree No. 22/2009 related to transfer pricing documentation requirements. The amendment effectively increases the validity of an APA to 6 years. Under the new rules taxpayers recharging the
See MoreOECD issues a revised discussion draft on intangibles
For some time the OECD has been conducting a project on transfer pricing aspects of intangible assets including consideration of the definition and valuation of such assets. A discussion draft was issued on 6 June 2012 and followed up by a
See MoreTransfer Pricing Brief: July 2013
Australia TPA Rule- New subdivisions 815-B to 815-E ITAA 1997 was enacted on 2 July 2013. Brazil Applicable Methods- Updates on applicable methods for import transactions. Germany TPA Rule-Legislation passed on 29 June 2013 and effective
See MorePoland: Amendments on transfer pricing guidelines come into force
The amendment of the Transfer Pricing Ordinance was published in the Official Journal No. 768/2013 on 3 July 2013, in a decree of Poland’s Ministry of Finance.The decree implements the provisions of the 2010 OECD Transfer Pricing Guidelines for
See MoreFrance: Greater transfer pricing documentation burden on taxpayers
The government of France has introduced a new bill with an effort to prevent tax evasion. The bill is expected to bring a greater compliance burden to taxpayers. According to the draft law companies are required to submit and file their
See MoreFrance is looking to review transfer pricing provisions
A report published by the Inspectorate General for Finance (IGF) on 6 June indicates that France is looking to review transfer pricing aspects of its tax code in order to better impose the arm’s-length principle. The French sanctions and
See MoreChile: Circular notifying transfer pricing changes
The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source
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