Ukraine: New transfer pricing rules
A law “On the Amendments to the Tax Code of Ukraine Regarding Transfer Pricing” passed its second and final reading on 4 July 2013 and was adopted by the Ukrainian Parliament. This legislation will become effective from 1 September
See MoreRussia- Clarification on documentation to verify appropriate transfer pricing method
The Ministry of Finance of Russia has issued public letter No. 03-01-18/26965 in relation to transfer pricing documentation on July 11, 2013 that clarifies process for preparing and submitting transfer pricing documentation for a particular
See MoreIndia: Criteria for manual selection of cases for transfer pricing audit
Instruction No. 10 of 2013 has been issued by the Central Board of Direct Taxes (“CBDT”) on 5th August 2013 which specifying the procedures and criteria for manual selection of cases by the tax administration for audit/ scrutiny for financial
See MoreHungary: amendment to transfer pricing documentation rules
The Ministry of Finance of Hungary issued an amendment of Decree No. 22/2009 related to transfer pricing documentation requirements. The amendment effectively increases the validity of an APA to 6 years. Under the new rules taxpayers recharging the
See MoreOECD issues a revised discussion draft on intangibles
For some time the OECD has been conducting a project on transfer pricing aspects of intangible assets including consideration of the definition and valuation of such assets. A discussion draft was issued on 6 June 2012 and followed up by a
See MoreTransfer Pricing Brief: July 2013
Australia TPA Rule- New subdivisions 815-B to 815-E ITAA 1997 was enacted on 2 July 2013. Brazil Applicable Methods- Updates on applicable methods for import transactions. Germany TPA Rule-Legislation passed on 29 June 2013 and effective
See MorePoland: Amendments on transfer pricing guidelines come into force
The amendment of the Transfer Pricing Ordinance was published in the Official Journal No. 768/2013 on 3 July 2013, in a decree of Poland’s Ministry of Finance.The decree implements the provisions of the 2010 OECD Transfer Pricing Guidelines for
See MoreFrance: Greater transfer pricing documentation burden on taxpayers
The government of France has introduced a new bill with an effort to prevent tax evasion. The bill is expected to bring a greater compliance burden to taxpayers. According to the draft law companies are required to submit and file their
See MoreFrance is looking to review transfer pricing provisions
A report published by the Inspectorate General for Finance (IGF) on 6 June indicates that France is looking to review transfer pricing aspects of its tax code in order to better impose the arm’s-length principle. The French sanctions and
See MoreChile: Circular notifying transfer pricing changes
The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source
See MoreUkraine: penalty for failure to submit a controlled transaction report
From 1st September 2013, under the new transfer pricing law introduced in Ukraine, certain transactions between related and unrelated parties will be subject to the arm’s length principle and will be treated as controlled transactions under the
See MorePortugal: Madeira’s International Business Center regime transfer pricing deadline
Among other tax incentives, the new Madeira International Business Centre (MIBC) regime introduced by Portugal provides reduced corporate income tax rates of 4% (in 2012) and 5% between 2013 and 2020. Under the new regime companies are required to
See MorePeru: Changes to transfer pricing documentation requirements
The Resolution 175-2013 of Peru sets out regulations concerning new transfer pricing documentation requirements which have become effective from 1 June 2013. According to the new rule taxpayers subject to the transfer pricing rules are required to
See MoreIndia: Documentation rules for transactions with “notified jurisdictional areas”
Section 94A to the Income Tax Act, 1961 empowers the Indian Government to blacklist certain jurisdictions which do not effectively exchange information with India. Those jurisdictions are classified as “notified jurisdictional areas.” The
See MoreChina: Selecting the appropriate transfer pricing method in the automotive sector
China’s State Administration of Taxation (SAT) takes the view that locally-based automotive enterprises that are apparently carrying out activities with limited function and risk are in fact performing valuable marketing efforts in China. The tax
See MoreGermany: Enactment of Cross-border profit allocation rules
Enactment of legislation regarding cross-border profit allocation was published in the Germany federal law gazette on 29 June 2013. Changes with regard to transfer pricing with the transposition into German tax law of article 7 of the OECD Model
See MoreTransfer Pricing Brief: June 2013
Australia Intangible property-Arrangements for the license or transfer of intangibles must conform to the arm's length principle. Financial services-A consultation on the thin capitalization rules was announced in the 2013 budget. Brazil Main
See MoreIndia: Internal TNMM will be given priority over external TNMM
The Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) recently it has been held that the transactional net margin method (TNMM) does not require a similarity of products and that internal TNMM analysis is acceptable for determining the
See More