Denmark: 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
See MoreAustralia introduced multinational anti-avoidance law, CbC reporting and increased penalties
The Treasurer of Australia introduced a Bill to implement the announced multinational anti-avoidance law to apply to foreign multinationals generating certain profits earned from Australia without an Australian permanent establishment;
See MoreUS: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions
IRS issued Treasury Decision 9738 on 14 September 2015 containing temporary regulations under Section 482 clarifying the application of the arm’s-length standard when multiple code sections. The temporary regulations apply to tax years ending on
See MoreUK: Summary of responses to penalties discussion document
On 17 September 2015 HMRC issued a summary of responses to a discussion document on penalties. The original discussion document published on 2 February 2015 put forward five principles that should be the basis for any tax penalty regime. These are
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreNetherlands-Publish Budget Proposal for 2016
The Dutch Ministry of Finance published its budget proposals for fiscal year 2016 on 15 September 2015. The budget proposals cover several tax law changes, including the application of the recent modifications of the European Union (EU)
See MoreThe Netherlands -Draft law implementing new transfer pricing documentation requirements
The Dutch State Secretary of Finance released a draft law providing changes to the Dutch Corporate Income Tax Act 1969 on 15 September 2015. The proposed changes involve supplementary transfer pricing documentation requirements in line with the
See MoreFrance: New article on transfer pricing assessments and withholding tax relief for repatriated profits
A new Article L. 62 A of the French tax procedure code was published in the official bulletin on 2 September 2015. The article provided rules that efficiently establish the tax treatment of certain profits transferred abroad by French taxpayers, and
See MoreUS: Treasury Department and IRS Released Temporary Regulations and Proposed Regulations to Clarify the Arm’s Length Standard
The Treasury Department and IRS released for publication in the Federal Register Temporary regulations (T.D. 9738) on 15 September 2015 to clarify the arm’s length standard and the best method rule under Code section 482 and the regulations
See MoreItaly: Extended the Statute of Limitation to Double in Criminal Tax Investigations
Italy has published the decree in the Official Gazette on 18 August 2015 on new anti-¬abuse rule and other measures to enhance legal certainty in tax matters. It became effective on 2 September 2015. The decree also modifies the rules on the
See MoreRomania enacts new Fiscal Procedure Code
The Romanian tax authority has published the revised Fiscal Procedure Code in the Official Gazette no. 545 dated 23 July 2015. The existing Fiscal Procedure Code is being updated by Law 207/2015 implementing new provisions with respect to tax
See More