Russia: Ministry of Finance clarifies the transfer pricing rules
The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax
See MoreUnited States – IRS releases transfer pricing audit “roadmap”
The IRS Large Business & International (LB&I) division has released a transfer pricing audit "roadmap" that is intended to be a practical, user-friendly toolkit organized around a notional 24-month audit time-line. The roadmap has been
See MoreOECD releases paper on transfer pricing documentation
On 30 January 2014, as part of the action plan on base erosion and profit shifting, the OECD published a discussion draft on transfer pricing documentation. This discussion draft takes the form of a revised Chapter V of the OECD Transfer Pricing
See MoreItaly’s Transfer Pricing Changes In 2014
Italy has introduced a number of transfer pricing-related changes within its Finance Act 2014 (Law No 147/2013). These changes will have an effect on both administrative procedures and fundamental transfer pricing concepts. Article 1, Paragraph 281
See MoreItaly dealing with transfer pricing legislation domestically
According to a verdict of the Italian Supreme Court in July 2013, internal transfer prices must follow the arm’s-length principle. Italy has been adopting international transfer pricing rules similar to those in the rest of Europe. The Supreme
See MoreGreece- Transfer Pricing Requirements regarding Financial Services and APA
The following requirements relative to financial services and Advance Pricing Agreement (APA) are described below: Financial Services: Financial services must follow the arm's length principle. It should also be noted that interest is deductible
See MoreBrazil – Ruling permits taxpayers to align their transfer pricing policies
According to a recent ruling by the Brazilian tax authority taxpayers should be able to better align their transfer pricing policies to eliminate potential contingent liabilities, reduce taxable adjustments, and/or eliminate the double taxation
See MoreBelgium: Transfer pricing audits process
Likely high-risk targets for audits are highly leveraged companies, those with large tax losses carried forward, and those with fluctuating profits. Belgium has increased the number of transfer pricing audits and expanded the team of transfer
See MoreTransfer Pricing Brief: January 2014
Argentina From 3 January 2014 there is a monthly reporting requirement for certain domestic transactions on the Argentinian market using Form F968. France Draft legislation introducing a presumption that profits are received if functions and
See MoreUS agrees to tax talks with India under mutual agreement procedure
Following an approach by India the US tax authorities for finding a solution to tax cases of about 100 US companies that have opted for the Mutual Agreement Procedure (MAP), the US has now agreed for a meeting next month to discuss MAP, advance
See MoreOECD: BEPS-related transfer pricing documentation, country-by-country reporting draft guidance
On 31 January 2014 the Organization for Economic Co-operation and Development (OECD) released an initial draft of revised guidance on transfer pricing documentation and country-by-country reporting. This is related to Action 13 under the Base
See MoreSwitzerland: Safe harbor rules apply to intra-group interest rates
Under a Circular of 30 January 2014 the safe harbor interest rate on loans received by shareholders or related parties denominated in CHF are 1.5% on loans financed through equity, or for loans financed through debt the safe harbor rate is the
See MoreVietnam – detailed guidance on APA process effective 5 February 2014
Following the introduction of Advance Pricing Agreements (APA) in the Revised Law on Tax Administration, Vietnam’s Ministry of Finance (MoF) issued Circular No. 201/2013/TT-BTC (Circular 201) providing detailed guidance on the APA application
See MoreTurkey: Specific Transfer Pricing Compliance
An annual transfer pricing report must be prepared by the date of the annual tax return. The transfer pricing rules also specify documentation that must be maintained. Listed companies may also be required to submit a report on controlled
See MoreSlovenia- Audits time limits
There is no fixed time limit within which a tax audit may take place. The statute of limitations is normally ten years but may be extended for the duration of legal procedures in connection with collecting
See MoreMalaysia: Audits process
Under the transfer pricing audit framework for transfer pricing audit effective from 1 April 2013, a taxpayer may be selected for audit based on the significance of its controlled transactions before taking into account other risk analysis. The time
See MoreTransfer Pricing Brief: December 2013
Australia The ATO's Base Erosion and Profit Shifting (BEPS) team is undertaking a compliance initiative called the International Structuring and Profit Shifting Project (ISAPS project). Brazil Penalties may also apply for non-reporting of
See MoreVietnam: APA regime procedures and rules
Vietnam’s Ministry of Finance has issued detailed guidance in Circular 201/2013/TT_BTC dated 20 December 2013, for the advance pricing agreement (APA) regime, which was added to the income tax law in July 2013. The new guidance is effective from 5
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