China-US: Third Bilateral Advance Pricing Agreement Signed
In September 2013, China’s State Administration of Taxation and the U.S. Internal Revenue Service reached an agreement in principle on their third bilateral advance pricing arrangement. China and the United States concluded their second bilateral
See MoreTransfer Pricing Brief: October 2013
Azerbaijan A Bill on transfer pricing is being re-introduced to parliament and if approved will take effect from 1 January 2014. Brazil Thin capitalization rules apply to restrict the interest deduction unless the value of the debt does not
See MoreSweden –tax audits require due process
In a recent ruling, the Administrative Court in Stockholm held that it was the duty of Swedish tax agency to communicate documents to the taxpayer in a case relating to the taxation of carried interest. The due procedures had not been followed by
See MoreOECD publishes comments received on intangibles
The OECD has published on its website the comments received by interested parties on its revised discussion draft on transfer pricing aspects of intangibles. The input received from more than sixty commentators will be discussed by the OECD’s
See MoreOECD publishes comments on white paper on transfer pricing documentation
The OECD has published comments received on the White Paper on transfer pricing documentation issued on 30 July 2013. The comments received from more than forty commentators are to be discussed by Working Party No. 6 of the OECD’s Committee on
See MoreTransfer Pricing Brief: September 2013
Brazil Under Ordinance 427/2013 where the taxpayer is the lending party a spread of 2.5% is to be added to the minimum interest rate. Ordinance 427/2013 sets a maximum spread of 3.5% for purposes of calculating the tax deduction for
See MoreGreece: Current transfer pricing legislation changes
Recently, major transfer pricing regulation changes have taken place in Greece. A bill was approved on 29 August 2013 by the Greek Parliament to expand the deadline for disclosing to the tax authority the inter-company transactions within a group
See MoreAustralia: Profit shifting through the artificial loading of debt
Two key issues have emerged for taxpayers, with the arrival of an Australian Treasury Paper, addressing profit shifting through the artificial loading of debt in Australia. Effective from 1 July 2014, the safe harbour for debt has been diminished
See MorePoland: Transfer pricing for business restructurings
Poland’s Finance Ministry issued decrees that bring the transfer pricing provisions of Poland’s tax law into line with international transfer pricing standards on September 3, 2013 and the decree effective from 18 July 2013. The decrees
See MoreAustralia: Prepare for an Australian Taxation Office (ATO) review
Australia is increasingly giving attention to transfer pricing issues and has recently introduced changes in the law to align the transfer pricing rules more closely to the OECD Guidelines. Taxpayers need to be completely ready for an Australian
See MoreMexican Tax Authority increases focus on auditing supply chain structures
Recent developments within the Mexican Tax Administration Services (SAT) demonstrate an increased focus on auditing supply chain restructurings. This is in line with international trends in transfer pricing, for example the report on business
See MoreTransfer Pricing Brief: August 2013
Indonesia Certain small and medium enterprises may be taxed on the basis of 1% of turnover. Israel Lower rates apply to companies eligible under the Law for the Encouragement of Capital Investment. Malaysia A Transfer Pricing Audit Framework
See MoreAustralia: Effective date of new Transfer Pricing rules
The new transfer pricing rules introduced by Australia are effective for years starting on or after 1st July 2013 and will apply to the transactions of all multinational entities operating in Australia. Before documenting their assessment forms,
See MoreIndia – CBDT Releases Drafts on Transfer Pricing Safe Harbor Rules
India’s Central Board of Direct Taxes (CBDT) released draft transfer pricing “safe harbor” rules as part of an initiative by the government to reduce the number of transfer pricing audits and protracted disputes on 14th August 2013,. Under the
See MoreIndia – No transfer pricing adjustment required on certain interest-free advances
Recently, Income Tax Appellate Tribunal by a ruling rejected and deleted transfer pricing adjustments proposed with respect to a taxpayer’s interest-free advances made to its related party (a U.S. subsidiary) on a finding that the taxpayer had
See MoreUkraine: 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
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