Switzerland publishes safe harbor interest rate limits for 2024
On 31 January 2024, the Swiss Federal Tax Administration released two circulars concerning the safe harbor interest rate limits for shareholders and related party financing for 2024. The rates vary based on whether the financing is in Swiss francs
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Kenya raises fringe benefit tax and non-resident loan interest rates
On 22 January 2024, the Kenya Revenue Authority released a notice related to the market interest rate for fringe benefit tax purposes and the deemed interest rate for non-resident loans for January, February, and March 2024. The market interest
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Poland announces base interest rates for related party debt for 2024
On 3 January 2024, Poland’s tax authority published a release related to a notice on the base interest rates and margins for the safe harbor simplification for loan, credit, or bond transactions between related parties in 2024. The safe harbor
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India: CBDT updates safe harbor rules for intragroup financing
On 19 December 2023, the Central Board of Direct Taxes (CBDT) in India announced significant changes to the safe harbor rules for intragroup financing arrangements. These updates, outlined in Notification No. 104/2023, will take effect on 1 April
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US: IRS evaluating group membership to fix arm’s length interest rate
On 29 December 2023, the Office of Chief Counsel Memorandum announced that the IRS is considering group membership to determine the arm's length interest rate chargeable for intragroup loans and make a section 482 adjustment. The memorandum provides
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Germany: Bundesrat approves secondary credit market promotion Act
On 14 December 2023, upper house of parliament (Bundesrat) granted approval to the Secondary Credit Market Promotion Act. The Act had already received approval from the German Bundestag (lower house of parliament) on 13 December 2023 and is
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Hong Kong approves bills to amend asset disposal gain regimes
The Hong Kong Inland Revenue Department passed bills to amend further Hong Kong's refined foreign-sourced income exemption (FSIE) regime, including asset disposal gains and introducing safe harbor rules for onshore equity disposal gains. This
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Australia increases interest rate for simplified transfer pricing record-keeping options for loans
On 8 November 2023, the Australian Taxation Office (ATO) released an updated version of practice compliance guideline on simplified transfer pricing record-keeping options (PCG 2017/2). The updates outline the safe harbor interest rate for the
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India: CBDT extends transfer pricing Safe Harbor Rules
On 9 August 2023, the Central Board of Direct Taxes (CBDT) issued a Notification No. 58/2023, to extend the applicability of the transfer pricing safe harbor rules. The extension applies for the financial year 2022-23 and 2023-24 assessment years.
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India: CBDT issues notification to set arm’s-length variation for 2023-2024
On 26 June 2023, the Indian Central Board of Direct Taxes (CBDT) has issued Notification No. 46/2023, setting arm's-length pricing variation limits for the 2023-24 assessment year. The limits are 1 percent for wholesale trading and 3 percent for
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OECD: Consultation Document on Transfer Pricing for Minerals
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework. This is a draft toolkit to support developing countries in combating base erosion and profit shifting relating
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Serbia: MoF adopts arm’s length interest rates for 2023
On 29 March 2023, the Serbian Ministry of Finance has approved the rulebook on arm’s length interest rates for 2023. The rulebook will be effective from 6 April 2023. Interest rates in accordance with “arm’s-length” principle that applies
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Switzerland publishes safe harbor interest rates for 2023
The Swiss Federal Tax Administration (SFTA) recently released Circular Letter No. 203 and Circular Letter No. 204 on 7 and 8 February 2023, respectively. These circulars provide safe harbor interest rates for intercompany loans and advances in Swiss
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On 16 December 2022, the Serbian Ministry of Finance published the Rulebook on arm’s Length interest rates applicable for 2022 that applies to related parties’ loans. The rulebook comes into force on 24 December 2022. Taxpayers can use the
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Australia: ATO releases updated interest rate for simplified transfer pricing record keeping options for loans
On 17 November 2022, the Australian Taxation Office (ATO) published an updated version of Practical Compliance Guideline (PCG) 2017/2 related to the eligibility criteria for applying simplified transfer pricing record keeping options for low level
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Australia: Budget proposal for FY 2022-23
On 25 October 2022, the Australian Treasurer Jim Chalmers delivered the Federal Budget for fiscal year 2022-23. The key tax measures are as follows: Thin capitalization The Budget amended the thin capitalization rules to limit debt deductions
See MoreBrazil and OECD present outline of new transfer pricing rules
On 12 April 2022 an event was held to present the outline of the new transfer pricing rules drafted by Brazil following a consultation process with the OECD. After Brazil had expressed the intention to become a full OECD member, Brazil and the
See MoreSingapore publishes TP Guidelines on indicative margin for related-party loans
On 4 January 2022, the Singaporean Inland Revenue Authority updated transfer pricing guidelines to set the 2022 indicative margin at 1.8% for related-party loans. The indicative margins are applied on each related party loan not exceeding
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