Bulgaria: 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
See MoreEU: JTPF presents comments received on the discussion paper on the Arbitration Convention
The Joint Transfer Pricing Forum (JTPF) held a meeting in Brussels on 6 March 2014at which the following items were discussed: – Information by the European Commission on ongoing issues; and – Arbitration
See MoreUruguay’s Tax Authority Reveals 2014 Targets
The Uruguayan tax authority (DGI) has recently revealed its 2014 audit targets. For 2014, the DGI indicated that it plans to conduct 1,350 tax audits in the year. This includes 90 audits for taxpayers whose turnover exceeds UYU50m (USD2.2m), and at
See MoreIndia: Tribunal finds reimbursed advertising expenses were at arm’s length
The Mumbai Bench of the Income tax Appellate Tribunal has upheld an administrative action by the Commissioner of Income tax, to reject a proposed transfer pricing adjustment for advertising expenses reimbursed by the taxpayer to its related
See MoreColombia: Information regarding comparable data range and segmented data uses
In accordance with the Regulatory Decree 3030 of December 2013, there is an economic link between the parties if the transaction is between a branch and home office, a transaction involving a permanent establishments, a related party transaction
See MoreTransfer Pricing Brief: February 2014
Argentina Transfer Pricing Requirements (TP)- TP requirements also apply to transactions carried out with individuals or legal entities located, organized or established in low or no tax jurisdictions. Australia Financial Services- On 16
See MoreSouth Africa – Transfer pricing, cross-border proposals in 2014 budget
South Africa’s 2014 budget contains proposals for changes to the transfer pricing rules and cross-border taxation. Among the transfer pricing and cross-border tax provisions in the 2014 budget are the following measures: Secondary adjustment for
See MoreColombia: Updates on documentation threshold’s, audit penalty and APA
According to the Regulatory Decree 3030 of December 2013, transactions over 32,000 UVT by type of transaction are subject to transfer pricing analysis only if the total amount of the transactions exceeds 61,000 TVU. In the case of transactions with
See MoreFrance – Creation of new program for APAs and MAPs
The French tax authorities have announced the creation of a new program—Mission d’expertise juridique et économique internationale (MEJEI) - which will be responsible for both advance pricing arrangements (APAs) and mutual agreement procedures
See MoreNigeria: Potential risks in transfer pricing regulations “safe harbor”
Regulation 15 of the Nigerian transfer pricing regulations provides for a transfer pricing safe harbor. A safe harbor is a statutory provision that relieves a given category of taxpayers or transactions from specific obligations otherwise imposed by
See MoreRussia: 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
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