Tanzania: Government issues new Transfer Pricing Regulations 2018
On April 27, 2018,Government has published new Income Tax (Transfer Pricing) Regulations of 2018. The regulations have issued on November 2018, which replaces the Income Tax(Transfer Pricing) Regulations 2014. This provides extra requirements
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreUS: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreAustralia: ATO publishes Diverted profits tax guidance
The Australian Tax Office (ATO) published the final form of the Practical Compliance Guideline (PCG) 2018/5 Diverted profits tax (DPT) and Law Companion Ruling (LCR) 2018/6 Diverted profits tax. The PCG aims to assist affected clients and their
See MoreSweden: Tax Authority releases updated guidance on hard-to-value intangibles
On 13 September 2018, the Swedish tax authority published an update of transfer prices guidance on intangible assets consistent with OECD's difficult-to-measure intangible assets (HTVI) guidance. The OECD HTVI Guidance offers tax authorities with a
See MoreIsrael: 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 MoreNigeria: Areas where CCAs may conflict with domestic law
The Government has observed almost six years of significant efforts to align its domestic tax laws and regulations with international initiatives on modernization of its tax principles and enhancement of transparency and disclosure requirements.
See MorePeru: Published Amendments to the Transfer Pricing Provision in the Official Gazette
Peru published the Legislative Decree No. 1369 (the Decree) on 2 August 2018 in the Official Gazette. The degree amends the transfer pricing provision of the Income Tax Law in order to be aligned with the BEPS project. The main amendments to the
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 MoreAustralia: ATO publishes draft guidance on transfer pricing issues
The Australian Taxation Office (ATO) has issued Draft Schedule 2 to Practical Compliance Guideline (PCG) 2017/1 ATO compliance approach to transfer pricing issues related to centralized operating models involving procurement, marketing, sales and
See MoreAustralia updates international dealings schedule for 2018 tax year
The Australian Taxation Office (ATO) has released the 2018 International dealings schedule (IDS) and their instructions for 2018 tax years. The IDS must be lodged by businesses that provide a response at the trigger questions of the relevant
See MoreUS: IRS issues additional guidance for computing the “transition tax” on foreign earnings
On 2 April 2018, the Treasury Department and the Internal Revenue Service published additional guidance (Notice 2018-26) for computing the “transition tax” on the untaxed foreign earnings of foreign subsidiaries of U.S. companies under the Tax
See MoreIreland: Guidelines on low value intra-group services
On 15 March 2018, Irish Revenue has published an eBrief No. 037/18 regarding guidelines on transfer pricing for low value intra-group services. The purpose of Tax and Duty Manual Part 35A-01-03 is to provide guidance to taxpayers regarding
See MoreBrazil releases Private Ruling regarding deduction of payments for certain Intra-group services
Brazil has recently released Private Ruling 1001 of 9 January 2018 regarding the deduction of certain cross-border payments to a foreign subsidiary, including strategic decision support, information management, risk management and management of the
See MoreUK: Autumn Budget Announcements 2017
The UK’s autumn budget measures were announced on 22 November 2017. Important measures affecting business are as follows: R & D Tax Relief The Research & Development Expenditure Credit (RDEC) rate available to companies claiming under
See MorePoland: Draft bill amendment regarding tax deductibility of intra-group charges
Poland’s Public Finance Commission of the Lower Chamber of Parliament has debated and passed noteworthy changes of the current draft bill on 24th October 2017. Under the draft bill issued by the Government in July, tax deductibility of various
See MorePoland: A new version of a draft bill to amend corporate income tax law
Recently, a new version of a draft bill to amend Poland’s corporate income tax law (and also to amend the individual income tax law) was submitted to the parliament. The amendment will most likely come into effect on 1 January 2018. Main changes
See MoreColombia changes rules of amortization of intangible assets
Colombian National Tax Authority (DIAN) has published a ruling regarding the application of amortization of intangible assets. In accordance with ruling, amortization method of an intangible must be decided based on the accounting rules, as long as
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