Israel: Tax Authority publishes Circulars regarding transfer pricing issues
The tax authorities (ITA) have recently published final versions of two professional Circulars, entitled Circular 11/2018 and Circular 12/2018, stating the ITA's expected profit levels for marketing services and for low-risk distributorship
See MoreCroatia: MoF publishes a draft bill covering various sectors
The Finance Minister, Zdravko Marić, on August 16, 2018, published draft bill on amendments to the Law on administrative cooperation in tax matters. This Act shall enter into force on the eighth day after its publication in the Official Gazette
See MorePoland releases draft law amending transfer pricing rules
On 16th July 2018, Poland has released a bill to amend the country's transfer pricing rules in line with the results of the BEPS project and the OECD transfer pricing guidelines 2017 in order to improve the taxation of large multinational companies.
See MoreTaiwan: MoF announces Safe harbor exemption
Taiwan's Ministry of Finance (MoF) announced a “safe harbor” exemption with respect to Master file and country-by-country (CbC) reporting On 11th December 2017. Transfer pricing guidance issued in November 2017 (and known in English as
See MoreSweden: Proposal for major corporation tax reforms
The Swedish Government on 20 June 2017 issued a statement proposing important changes in the area of corporate taxation. The main proposals are summarised below: According to the announcement the deductibility of the net interest expense would
See MoreIndia: CBDT notifies new safe harbour regime for cross-border transactions
The Central Board of Direct Taxes (CBDT) on 7 June 2017, has issued a new, relaxed, safe harbour regime in order to reduce transfer pricing disputes. The move is aimed at providing certainty to taxpayers, aligning safe harbour margins with industry
See MoreSingapore: IRS publishes Transfer pricing guidelines 2017
The Inland Revenue Authority of Singapore published the 4th version of transfer pricing guidelines on 12 January 2017, demonstrating compliance with international transfer pricing standards. The published guidelines explicitly refer to the Base
See MoreNigeria: Safe harbour concept in the transfer pricing regulations
The transfer pricing regulations in Nigeria are formally known as the ‘Income Tax (Transfer Pricing) Regulations No 1, 2012”. These regulate contacts between connected taxable persons or controlled transactions. The objective of the
See MoreFinland: Government Issues Proposal To Change Transfer Pricing Rules
The Finnish government issued a draft proposal on 7 January 2015 that would amend the transfer pricing rule in section 31 of the Tax Procedure Act. Comments are due by 20 February 2015. Information on the effective date for the amendment is not
See MoreAustralia: Taxation Ruling 2014/8 introduces by the Australian Taxation Office (ATO)
Taxation Ruling 2014/8 gives outlines on what needs to be included in the documentation if the taxpayer is to meet the standard of a "reasonably arguable position" and avoid penalties, and sets out five key questions for preparation of
See MoreSpain: Modified legislation on transfer pricing published
On 28 November 2014, Laws 26/2014 and 27/2014, which modify the most important Spanish tax laws were published in the Spanish Official Gazette. This new legislation will generally come into force on 1 January 2015. This new legislation modified in
See MoreAustralia – Reduces safe harbor for thin capitalization
Australia recently reduced the safe harbor rule for thin capitalization limit from 75% to 60%, corporate groups may want to consider what steps to take with respect to their thin capitalization positions. With effect from 1 July 2014 the permitted
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 MoreSwitzerland: Safe harbor rules apply to intra-group interest rates
Under a Circular of 30 January 2014 the safe harbor interest rate on loans received by shareholders or related parties denominated in CHF are 1.5% on loans financed through equity, or for loans financed through debt the safe harbor rate is the
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 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 MoreOECD: Revised Section E on Safe Harbours
The Organisation for Economic Co-operation and Development (OECD) Council approved the Revised Section E on safe Harbours in Chapter IV of the Transfer Pricing Guidelines, on 16th May 2013. The Revised Section E (Section E) contains only nine pages,
See MoreUS: IRS invites public comments on Bilateral Safe Harbors for Certain Transfer Pricing Issues
The Internal Revenue Service (IRS) announced on March 15, 2013, that it is consulting interested parties on the development of a model memorandum of understanding (MOU) between Competent Authorities relating to transfer pricing safe harbors for
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