OECD – Transfer pricing documentation and country-by-country reporting consultation
The OECD is holding a consultation on 19 May 2014 to consider transfer pricing documentation and country-by-country reporting. This follows the publication of a discussion draft in relation to the BEPS (base erosion and profiting shifting) Action
See MoreMexican tax reform of 2014 imposes deadlines for Maquiladora companies
The Mexican tax reform of 2014 has introduced a number of important changes for maquiladora enterprises. The changes apply to companies that are operating under the requirements of the Decree for the Promotion of the Manufacturing, Maquiladora and
See MoreBelgium – Tax Penalties for Non-Compliance ranging 10% to 200%
Belgium is determined to enforce tax penalties to ensure that taxpayers submit their latest tax returns on time. The Finance Ministry has encouraged taxpayers to send in a complete and correct income tax declaration for 2013, to avoid incurring a
See MoreIndia: Hyderabad Tribunal rules on transfer pricing aspects of corporate guarantee
The Hyderabad Income Tax Appellate Tribunal (ITAT) has issued a ruling that concerns certain transfer pricing issues from a corporate guarantee issued to a bank by associated enterprises of a borrower. The case is Four Soft Pvt Lrd. The case
See MorePeru: Published regulation for advance pricing agreement
The tax authority's Resolution 377-2013/SUNAT, published in the Official Gazette on 29 December 2013.Accordance with the Resolution 377/2013, intention to negotiate an APA should be expressed in writing to SUNAT which must reply within 15 days.
See MoreUS: Bankruptcy Court rejects IRS transfer pricing adjustment
The US Bankruptcy Court for the Middle District of North Carolina (Greensboro Division) has rejected an IRS transfer pricing adjustment because the taxpayer would incorrectly considered to be an independent distributor Re: Case No. 09-10846C-11G, 18
See MoreTransfer Pricing Brief: March 2014
Austria Intangible property-From 1 March 2014 interest and royalty payments to certain related parties are not deductible for tax purposes if the recipient corporation is not subject to tax due to an exemption.Financial Services-From 1 March 2014
See MoreIndia shows decline in transfer pricing adjustments
The income tax department has estimated that the number of transfer pricing adjustments in 2014 so far has fallen by 14 percent by comparison to the previous year. This may indicate that taxpayers in India are becoming more aware of the transfer
See MoreNetherlands – Dutch taxpayer liable for Swiss captive subsidiary’s profits
A recent decision by a district Court in the Netherlands involved a Swiss captive insurance company that did not have any employees. The Court reached the decision that the tax authorities in the Netherlands were correct in levying tax on a related
See MoreIndia: Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions
In India many transfer pricing cases are heard in the Courts. These decisions can provide clarification of the operation of the transfer pricing rules in India and can therefore give potential investors more certainty about the transfer pricing
See MoreEuropean law used in Turkish transfer pricing case
Turkey has taken a step towards improving the rights of taxpayers by implementing a decision of the European Court of Human Rights (ECHR) in a transfer pricing ruling. The transfer pricing case involved allegations by the tax administration that a
See MorePortugal: Necessary requirements for Financial Services
In Portugal, a restrictions on the deduction of interest has announced that effects from 2013. Net financial costs are only deductible up to the higher of EUR 1 million (EUR 3 million before 1 January 2014) or 30% of profit before depreciation, net
See MoreBulgaria: Information regarding Transfer Pricing Documentation
An Appendix 4 has been added to the return in accordance with commencing on the tax return for 2013, to be used by taxpayers to report related party transactions and transactions with entities situated in a jurisdiction with a preferential tax
See MoreUS: Important information regarding intra-group services
The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also
See MoreOECD – Transfer pricing comparability data and developing countries
The OECD has prepared a paper in respect of transfer pricing comparability data and its use in developing countries. This is intended to find a response to concerns about the quality of comparable data available in developing countries. The lack of
See MoreNigeria – Companies requested to submit group transfer pricing documentation
In Nigeria the tax authority FIRS is asking taxpayers to send in transfer pricing documentation for the group to which they belong. Although there is no specific deadline they should do so as soon as possible and the documentation should be with the
See MoreMalaysia: increasing scrutiny of transfer pricing
The transfer pricing landscape in Malaysia continues to develop with the Malaysian tax authority becoming increasingly proactive and vigilant in examining the controlled transactions of multinational enterprises (MNEs). The intensity of tax audits
See MoreJapan: Increased focus on transfer pricing in tax audit
Transfer pricing audits in Japan are conducted separately from the general corporate tax audits, by a specialized transfer pricing audit team within the tax authority .The 2011 revision of the tax system in Japan included changes and clarifications
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