Australia: New Transfer Pricing Rules
On 22 November 2012, an exposure draft was released introducing new Australian transfer pricing rules with significant self assessment and documentation requirements. Interested parties were invited to comment on the exposure draft. The start date
See MoreIrish Revenue announces transfer pricing compliance monitoring approach
On 6 December 2012 it was published that the Irish Revenue released guidance on 26 November 2012 setting out how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997 The guidance
See MoreColombia: Transfer pricing documentation and APA requirements amended
It was reported on 29 August 2012 that, decree 1602, published in the Official Gazette of 27 July 2012, modifies some of the transfer pricing regulations established by Decree 4349 of 2004. Some of the most important modifications, applicable as
See MoreTransfer Pricing Brief: August 2012
Belgium There are no specific provisions in relation to financial services, but fees must conform to the arm's length principle. Thin capitalization rules apply to restrict the tax deduction for interest on loans between related companies or loans
See MoreIndia- introduction of an APA program
The Finance Minister of India introduced the Finance Bill, 2012, on 16 March 2012 in which with respect to transfer pricing, the introduction of an advance pricing agreement (APA) program as well as other transfer pricing-related items has been
See MoreRussia- Introduces new Transfer Pricing Rules
New Federal Law FZ-227 of 18 July 2011 which enacted comprehensive transfer pricing rules entered into force on 1 January 2012. According to the new Law, companies falling under the scope of transfer pricing rules will be obligated to disclose
See MoreLithuania- APA
The amendment to the Tax Administration Law applicable from 1 January 2012, enables taxpayers to apply for advance transfer pricing agreements with the tax administrator. Agreements between taxpayers and the tax administrator on transfer pricing
See MoreUK: Latest Transfer Pricing Statistics Released
HM Revenue and Customs (HMRC) settled the UK’s Transfer Pricing rules such a way that the pricing of transactions between connected can result into an increased revenue yield. The internationally recognized ‘arm’s length principle’ is
See MoreNew transfer pricing form issued by Malaysia’s tax authority
Malaysia’s Inland Revenue Board (IRB) has issued a new form to collect information on transfer pricing compliance, and enforce transfer pricing rules for the corporate taxpayers. The IRB targeted the corporate taxpayers because they have
See MoreTransfer pricing gets intensive focus in Vietnam’s General Department of Taxation
During the late July 2011 Vietnam’s General Department of Taxation (GDT) and HCM tax authorities took several activities on transfer pricing (TP) which focused importantly on increasing awareness and strengthening the implementation of TP
See MoreAuthorities’ use of net-back approach in transfer pricing case has been overruled by the Russian Court
The Federal Arbitration Court of the Moscow Region rejected the Russian Tax Authorities’ attempt to adjust a taxpayer’s transfer pricing by applying the net-back approach. The net-back method are applied to oil production and operates by taking
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