Korea: Draft law for implementing BEPS-related transfer pricing requirements
The Ministry of Strategy and Finance of South Korea has released draft legislation for amending existing provisions of Korean law. The draft legislation generally follows Action 13 of the OECD/ G20 project on base erosion and profit shifting
See MoreCanada: CRA releases annual MAP report
The Canada Revenue Agency (CRA) has published its 12th annual report regarding its Mutual Agreement Procedure (MAP) programme. The report gives the objective, history, and present events of the MAP programme for the period from 1st April 2014 to
See MoreColombia- Tax haven transactions subject to transfer pricing regime
The National Tax Authority of Colombia published Ruling 20776 of 2015 according to which transactions carried out with tax haven jurisdictions in tax year 2014 are subject to the transfer pricing regime. According to article 260-7 of the Tax Code
See MoreChile: IRS issues guidelines regarding anti-avoidance rules
The Inland Revenue Service (IRS) in Chile has issued total 7 circulars including Circulars 65 and 68 on 23rd July 2015 for giving directions won the anti-avoidance rules enacted as part of Law No. 20780. The circulars contain limitations on the
See MoreUS: IRS Issued New Revenue Procedures on Competent Authority and Advance Pricing Agreement
The IRS has issued two revenue procedures on August 12, 2015 with details guidance to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement (APA) program. The proposed version of
See MoreEcuador-new regulations on transfer pricing documentation requirements
Recently Ecuador’s Internal Revenue Service (IRS) has issued regulations giving outlines to new transfer pricing documentation requirements. The new regulations require taxpayers to include substantial information on the economic substance of
See MoreAustralia: Stronger penalties to fight against multinational tax avoidance
The Government of Australia announced double the maximum administrative penalties that can be applied by the Commissioner of Taxation to large companies that enter into tax avoidance and profit shifting schemes. The increased penalties, under
See MoreAustralia: New transfer pricing documentation standards
On 6 August 2015, the Australian Treasury released exposure draft law to implement reporting requirements for large multinational businesses in line with recommendations by the OECD and G20. In the 2015-16 Budget, the Australian government announced
See MoreUS Treasury to develop regulations implementing CbC reporting requirement
US Treasury announced on 31 July 2015 that the US government intends to develop regulations implementing the OECD/G20 base erosion and profit shifting (BEPS) action plan guidance on country-by-country (CbC) reporting by multinational
See MoreUkraine: State Fiscal Service published letter regarding tax control over transfer pricing
The State Fiscal Service (SFS) published Letter No. 24525/7/99-99-22-01-02-17 issued on 7 July 2015 addressing the penalties levied for failure to submit transfer pricing (TP) documentation or to include relevant information about controlled
See MoreChina: Announcement on Cost Sharing Agreements
Recently, China’s State Administration of Taxation has promulgated the Announcement on Standardizing the Administration of Cost Sharing Agreements (the "Announcement 45") for implementation as of July 16, 2015. This announcement 45 is issued to
See MoreTransfer Pricing Brief: July 2015
India: Comparable data range: The Punjab and Haryana High Court confirmed a judgment in the case of CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 of a tax appellate tribunal that certain companies could be appropriate
See MoreUkraine: Cabinet of Ministers adopts new advance pricing agreement procedures
Ukraine’s Cabinet of Ministers published Resolution No. 504 on 25 July 2015 regarding conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes. The new Resolution replaces the former
See MoreIndia: Delhi Tribunal allows use of multiple-year data for purposes of determining arm’s length price
In the case of DCIT v. Innodata Isogen India Pvt. Ltd. , the Delhi Bench of the Income Tax Appellate Tribunal upheld a decision of the Commissioner of Income Tax (Appeals) to allow the taxpayer to use multiple-year data in determining the arm’s
See MoreIndia: Transfer Pricing Adjustment For Interest-Free Loan to Related Party
Recently, the Income-tax Appellate Tribunal upheld an interest adjustment on a loan that the taxpayer advanced to a related entity In the case of: Soma Textile & Industries Ltd. v. ACIT. Here the tribunal found that the comparable uncontrolled
See MoreSri Lanka: Commissioner General of Inland Revenue publishes gazette on Transfer Pricing Regulations
The Commissioner General of Inland Revenue has published gazette no. 1907/26 dated 25 March 2015 on Transfer Pricing Regulations. It was made available on the Government Printer’s website on 27 May 2015. The gazette requires the taxpayer to
See MoreSpain: BEPS country by country reporting provisions enacted
The Spanish Ministry of Finance published Royal Decree 634/2015 of 10 July 2015 in the Official Gazette on 11 July, 2015. The Decree contains corporate income tax regulations including (BEPS) country by country reporting requirements in line
See MoreGreece: tax authorities issue circular to clarify transfer pricing regulations
The Greek tax authorities issued circular no. POL 1142/02.07.2015 dated July 2, 2015 to explain transfer pricing (TP) documentation issues raised in light of the new Income Tax Law no. L. 4172/2013 and Tax Procedures Code no. L. 4174/2013. The
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