South Africa: Transfer Pricing Adjustments Regarding Withholding Tax Obligations
Under the income tax act, section 31(3), South Africa provide that any adjusted amount for transfer pricing and thin capitalization purposes, prior to 1 January 2015, constituted a deemed loan. The adjusted amount plus interest deemed to have
See MoreTransfer Pricing Brief: January 2015
Australia Requirement for Transfer Pricing Documentation- Taxpayers with a high risk transfer pricing profile will be held to more stringent requirements. Transfer Pricing Audits Penalty in Cases of Adjustments-25% penalty applies
See MoreSpain: Modifies the transfer pricing legislation
In the “Corporate Income Tax Reform 2015” enacted under the Law 27/2014 the following transfer pricing rules are amended; Scope of related-party transactions - The ownership requirement for related parties is increased from 5% (1% in the
See MoreCanada: Customs Notice permits import duty refund claims on transfer pricing adjustments
Basically, Customs Notices are issued to inform clients about proposed changes to customs procedures. Customs Notice N-15-001 has been published by the Canada Border Services Agency (CBSA) for deleting an obstacle to file import duty refund claims.
See MoreSpain: Government Announces New Country-by-Country Reporting Obligations for MNEs
The Spanish government on 20 January 2015 announced that it will issue regulations, expected to be adopted in the first half of 2015, that will require country-by-country reporting by multinationals. The new regulations would enter into force on 1
See MoreFrance: Increases Transfer Pricing Documentation Penalties
France’s 2015 Finance Bill, enacted on December 29, 2014, increased the penalties applicable in cases of failure to comply with the French transfer pricing documentation rules. The newly defined penalty for a failure to produce transfer pricing
See MoreIceland: Final regulation on transfer pricing documentation
Accordance with the Regulation No. 1180/2014 the Ministry of Finance issued the final regulation on transfer pricing on 16 December 2014, which entered into force on 1 January 2015. The final regulation clarifies that the transfer pricing rules and
See MoreJapan: Honda Succeeds in Transfer Pricing Case
The Tokyo District Court in the case of: Heisei 23 (2011) gyou-u No. 164 ruled on 28 August 2014 that, in using the residual profit split method, the profits to be attributed should include the special tax benefits enjoyed by the Brazilian
See MoreSingapore: New Revised Transfer Pricing Guidelines for 2015
The Inland Revenue Authority of Singapore (IRAS) publishes revised transfer pricing (TP) guidelines on 6 January 2015. The 2015 TP Guidelines are generally in line with the OECD Transfer Pricing Guidelines (2010) as well as some relevant areas of
See MoreFrance: New Tax Laws Permit Sister Companies To Consolidate
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force. According to new law, the changes are below; New rules permitting sister companies to f for tax purposes. A reduction in the real estate
See MoreTransfer Pricing Brief: December 2014
Argentina Compliance-Decree 2103/2014 created a special unit to monitor cross-border trade and coordinate the work of the various government bodies to ensure the correct application of the law on international trade. Australia Transfer
See MoreUkraine: Parliament Approves Tax Reform Plans
The Ukraine Parliament approved a package of laws on December 28, 2014, which significantly amend the system of taxation in Ukraine. Key changes are summarized below; General Provisions Number of taxes was decreased from 22 to 11 (including 2
See MoreAustralia: Practice Statement PS LA 2014/2 released by the Australian Taxation Office
The Australian Taxation Office (ATO) released guidance on what the ATO expects taxpayers to prepare in order to comply with the transfer pricing laws and manage related risks on 17 December 2014. According to guidance 25% penalty applies and
See MoreChina issues Circular Caishui [2014] No. 59 to extend the current preferential corporate income tax treatment
China’s Ministry of Finance, the State Administration of Taxation, Ministry of Commerce, Ministry of Science and Technology and National Development and Reform Commission jointly issued Circular Cai Shui no 59 On 8 October 2014, has extended the
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreKorea: Unilateral APA program introduced
A simplified APA (Advance Pricing Agreement) program is to be introduced from 2015 for the conclusion of unilateral APAs by manufacturers, wholesalers, retailers or service providers with revenue under KRW 50 billion. Applicants will be able to
See MoreSpain: Modified legislation on transfer pricing published
On 28 November 2014, Laws 26/2014 and 27/2014, which modify the most important Spanish tax laws were published in the Spanish Official Gazette. This new legislation will generally come into force on 1 January 2015. This new legislation modified in
See MoreIndia & Japan: First bilateral APA signed
The Central Board of Direct Taxes (CBDT) signed a bilateral Advance Pricing Agreement (APA) with a Japanese company on 19 December 2014. This is India’s first bilateral APA which has been signed for a period of 5 years. Moreover, CBDT was proud to
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