Slovak 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
See MoreTransfer Pricing Brief: July 2014
Brazil Financial Service- a tax on financial transactions also applies in the case of foreign exchange transactions. Germany Transfer Pricing Rules- Guidance issued by the BMF in June 2014 defines important terms for transfer pricing
See MoreSouth Africa: Tax authority proposes to revise “secondary adjustment” treatment
South African tax authority has been proposed that South Africa’s transfer pricing legislation relating to “secondary adjustments” be amended. The proposal placed to the Draft Tax Laws Amendment Bill 2014. Generally, a “secondary
See MoreIndia: Amended the transfer pricing rules in budget 2014
On 10 July 2014, the Finance Minister proposes amendments to India’s transfer pricing rules in India’s budget of 2014. The Budget 2014 proposes to amend the rules to provide that an APA entered into with regard to a future transaction may also
See MoreCanada:The Court of Appeal’s decision regarding penalties in transfer pricing case
The decision regarding the case of The Minister of National Revenue v. Sifto Canada Corp has given by the Federal Court of Appeal on May 28, 2014. The tax authorities were appealing a decision of the Federal Court, upholding a decision of
See MoreFrance- Deadline for filing additional Transfer Pricing Statement
The French Government adopted a new additional transfer pricing documentation requirement codified under Article 223 quinquies B of the French General Tax Code. According to the new rule certain taxpayers will be able to file a “reduced”
See MoreSlovak Republic: New improvements in Transfer Pricing
The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished
See MoreUkraine: Tax authorities updated on certain transfer pricing issues
On 1 July 2014, the Ministry of Revenues and Levies of Ukraine has issued Order No.368 which approves an updated of "Generalized Tax Consultation on Application of Certain Provisions of the Tax Legislation on Transfer Pricing." The Order
See MoreTransfer Pricing Brief: June 2014
Canada Penalty for documentation failurePenalties may apply if the taxpayer does not make reasonable efforts to arrive at the arm's length price.Transfer pricing documentation requirement The documentation must outline the organization of the
See MoreMalaysia: Inclusion of the new check-the-box requirements and its consequences
A new check-the-box named “Box R4” has been inserted on the 2014 tax return form (Form C) of Malaysia to declare by the corporate taxpayer for the confirmation that the preparation of contemporaneous transfer pricing documentation is complied in
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