Panama: MHQ companies are subject to transfer pricing regulations
Law No. 57 was published on October 24, 2018 in the Official Gazette, which amends the multinational headquarters regime (MHQ regime). It contains provisions on applying transfer pricing regulations to transactions conducted by entities with an MHQ
See MoreSweden: Tax Agency updates Transfer Pricing Guidance on Profit Splits method
On 29 August 2018, the Swedish Tax Agency (Skatteverket) has updated its transfer pricing guidance to incorporate the OECD guidance on the application of the transactional profit split method, which was revised as part of the work for BEPS Action
See MoreNetherlands publishes new transfer pricing decree
The Dutch Ministry of Finance published a new transfer pricing decree nr. 2018-6865 on 22 April 2018, which was published in the State Gazette on 11 May 2018. The Decree is in line with the outcomes of the Base Erosion and Profit Shifting (BEPS)
See MoreItaly issues final transfer pricing regulations on the application of the arm’s length principle
Italy issued final transfer pricing regulations on May 14 regarding the application of the arm’s length principle. The publication follows the release of a draft for public consultation in February and a consultation in May. The guidance supports
See MoreItaly: Draft transfer pricing regulations and corresponding adjustments
On February 21, 2018 the Italian Ministry of Economy and Finance released its draft transfer pricing rules to comply with the Article 8-10 OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The draft rules are declared in their website for
See MoreRussia: MoF clarification on application of thin capitalization rules in the context of tax treaties
Recently, the Ministry of Finance (MoF) issued a Guidance Letter (No. 03-03-06/1/87340) and clarified the application of domestic thin capitalization rules in the context of tax treaties. According to a statement by the MoF, interest paid by a
See MoreUkraine: SFS publishes guidance letter on definition of related parties
On 5 February 2018, the State Fiscal Service (SFS) published Guidance Letter No. 204/6/99-99-15-02-02-15/IPK of 18 January 2018 clarifying definition of related parties regarding holding ownership of a director who owns the corporate
See MoreUkraine clarifies the definition of controlled transactions for transfer pricing purposes
On 19 January 2018, the State Fiscal Service (SFS) released Guidance Letter No. 119/6 / 99-99-15-02-02-15 / IPK of January 12, 2018, which defines the definition of controlled transactions for cross border transaction purposes. Under the amendments
See MoreLithuania proposes new transfer pricing rules
On 15 January 2018, a draft order amending the regulations of controlled transactions was issued by the Ministry of Finance of the Republic of Lithuania (to amend the Order No. 1K-123 dated 9 April 2004). The main points in the draft order are the
See MoreMozambique: Council of Ministers approves first transfer pricing regulations
On December 6, 2017, the Council of Ministers has approved the first Transfer Pricing (TP) Regulations by Decree 70/2017. The Decree became in force on or after the January 1, 2018. According to Decree, one company is considered to be related to
See MoreSlovak Republic: Government approves several tax amendments
The President has signed an amendment to Law No. 595/2003 Coll. on Income Tax on December 20, 2017. Some of the changes are given below: Related party transaction In accordance with the current amendment, the text of the related party definition
See MoreUkraine changes in Transfer Pricing Rules from January 1, 2018
On 7 December 2017, the Ukrainian Parliament passed the Law of Ukraine "On Amendments to the Tax Code of Ukraine and Certain Laws of Ukraine on Securing Balance of Budget Revenues in 2018” No. 2245-VIII (“Law”). The law came into force on 1
See MoreZambia: MoF approves amendments in transfer pricing regulation
The Minister of Finance (MoF) is set to approve changes in transfer pricing rules, including procedures for the valuation of the transfer pricing transactions between related entities and allow for taxable income adjustments and documentation
See MoreUkraine clarifies classification of transactions with a non-resident legal entity
On October 4, 2017, the State Fiscal Service (SFS) published Letter No. 1945/6 / 99-99-15-02-02-15 / IPK of September 13, 2017, which specifies the classification of transactions with a non-resident legal entity for the purpose of transfer
See MoreGuernsey: The Beneficial Ownership of Legal Persons Law enacted
The Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 came into force on 15 August 2017. The Law establishes the Office of the Registrar of Beneficial Ownership of Legal Persons, sets out the powers and functions of the Registrar, and
See MoreOECD: 2017 edition of the transfer pricing guidelines issued
On 10 July 2017 the OECD issued the 2017 edition of the OECD transfer pricing guidelines. The amendments made in the latest edition of the guidelines mainly arise from the transfer pricing aspects of the conclusions and recommendations of the
See MoreUkraine: SFS clarifies the definition of related parties for the recognition of controlled transactions
On 16 May 2017, the State Fiscal Service of Ukraine published a letter No. 9012/6/99-99-15-02-02-15 concerning the definition of related parties for the recognition of transactions controlled and guided by article 52 of the Tax Code of Ukraine. The
See MoreIndia: Latest update on country-by-country reporting
India has recently included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The first round of CbC reports, if applicable, must be submitted to the
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