Luxembourg: New Transfer Pricing rules from 2015
A new transfer pricing rules will take effect in Luxembourg from the year 2015 in line with international principles and OECD Tax Model convention providing adjustments of profit provisions if transfer pricing do not reflect the Arm’s Length
See MoreNigeria: Preparing for transfer pricing audit
A transfer pricing declaration and disclosure form will be the first returns filed in compliance with Nigeria’s transfer pricing regulations if returns of taxpayers having a December 2014 accounting year-end. By filing these returns, Nigeria’s
See MoreIceland: Released draft regulation on transfer pricing documentation
The Icelandic Ministry of Finance released the draft regulation on transfer pricing on 13 October 2014. According to the draft regulation outlining detailed transfer pricing rules was released on 13 October 2014 and when finalized this will apply
See MoreTransfer Pricing Brief: September 2014
Australia Transfer Pricing Documentation Requirement-Draft practice statement PS LA 3673 sets out the responsibilities in respect of transfer pricing under self-assessment.Penalty in cases of Adjustments- Draft practice statement PS LA 3672
See MoreChina: Transfer pricing application Process
Transfer pricing adjustments may be made in accordance with Circulars 3 and 16 "Internal Working Procedure (Trial) of Special Taxation Adjustment" and "Joint Assessment Procedure (Trial) for Key Cases of Special Taxation Adjustment". Accordance with
See MoreEU – Pan-European implications of VAT decision on cross-border services
The Court of Justice of the EU recently issued a judgment in a case that may have implications for multinational organizations with either branch operations or head office in EU Member States particularly those entities in the financial services
See MoreSlovenia: APA concluded for transfer pricing purposes
On 1 August 2014, the amendments to the Financial Administration Law (the Law) entered into force. According to the law, the Tax Procedure Act effective from 2007 introduced a system of tax rulings and from 1 August 2014 advance pricing agreements
See MoreFrance: Tax Authority Released The Final Version Of Abridged Documentation Report
The tax authorities of France released the final version of the tax form No 2257-SD on 16 September 2014 which is also known as the abridged documentation report, requiring some information; Information for MNE: Multinational Entity’s
See MoreSlovenia: Financial administration approved to conclude advance pricing agreements
In Slovenia, the amendments to the Financial Administration Law (the Law) entered into force on 1st August 2014. This Law Based on financial authorities is authorized to conclude advance pricing agreements (APA) for transfer pricing purposes. The
See MoreSlovak Republic: New guidance regarding transfer pricing documentation has been published
The Ministry of Finance has published new guidance on the contents of transfer pricing documentation (TPD) on August 20, 2014 that requires changes for most taxpayers. This alert summarizes the transfer pricing legislative developments as well as
See MoreSingapore: IRAS invites to comments on transfer pricing documentation requirements
The Inland Revenue Authority of Singapore (“IRAS”) invited comments by 24 September 2014 on its proposed update to Section 4 of the existing Singapore Transfer Pricing Guidelines relating to the transfer pricing documentation, which was first
See MoreTransfer Pricing Brief: August 2014
Australia Financial services-With effect from 1 July 2014 the permitted debt to equity ratio has been reduced from 3:1 to 1.5:1. Chile Main corporate income tax rate-Under the provisions of a modified tax bill published by the government the
See MoreCanada: A case regarding transfer pricing adjustments
In subsection 247(2) of the Income Tax Act, the transfer pricing adjustment rules apply if transactions undertaken by non-arm's length parties do not reflect arm's length terms and conditions. In “McKesson Canada Corporation v. The Queen”, Tax
See MoreCzech Republic: Documentation requirement for tax payer
From 1 January 2014 Czech taxpayers must send in a separate disclosure form entitled Overview of Transactions with Related Parties at the time of filing the corporate tax return. This applies to taxpayers with foreign related party transactions in
See MoreSpain: Supreme Court rules certain provisions of the transfer pricing regulations
The Spanish Supreme Court issued its final judgment regarding challenges the constitutionality of specific provisions of the transfer pricing regulations on 14 July, 2014. The Supreme Court focused the following areas; Secondary adjustment: The
See MoreMexico-Panama: Shared transfer pricing regime
The National Revenue Authority of Panama and Mexico's Tax Administration Service (SAT’s) shared transfer pricing experience in order to know how SAT manages the transfer pricing regime, and analysis its case selection process, and auditing on 14
See MoreAustralia – Reduces safe harbor for thin capitalization
Australia recently reduced the safe harbor rule for thin capitalization limit from 75% to 60%, corporate groups may want to consider what steps to take with respect to their thin capitalization positions. With effect from 1 July 2014 the permitted
See MoreUruguay-Tax authorities rule on application of transfer pricing study
The tax administration of Uruguay issued Ruling No. 5,975 on 18 June 2014. According to the ruling transfer pricing study will not be applicable in the case of financial operations between a Uruguayan branch and foreign parent. The ruling will
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