India: CBDT issues final rules for valuation of unquoted shares
The Central Board of Direct Taxes (CBDT) on 12 July 2017 has issued a notification prescribing the method for valuation of unquoted shares for the purposes of Section 56(2)(x) and Section 50CA of the Income-tax Act 1961. The rules will be effective
See MoreOECD: Comments received on draft HTVI implementation guidance
On 5 July 2017 the OECD published comments received in relation to the BEPS discussion draft on the implementation guidance on Hard-to-Value Intangibles (HTVIs). The comments received focus on a range of points including the uncertainty arising for
See MoreIndia: The tribunal removed the transfer pricing adjustment for intra-group services
The Ahmedabad Bench of Income-tax Appellate Tribunal, in the case of: SABIC Innovative Plastics India Pvt Ltd. (ITA No. 1125/Ahd/2014 - Assessment Year 2009-10 and IT (TP) No. 427/Ahd/16 - Assessment Year 2011-12), deleted the adjustment made by the
See MoreChina issues new TP and MAP rules
On 1 April 2017, The State Administration of Taxation (SAT) of China published a Bulletin-6 providing new transfer pricing (TP) guidance and strengthening the Mutual Agreement Procedure (MAP) process. Bulletin 6 is effective from 1 May
See MoreChina concludes first cost sharing agreement APA
The State Administration of Taxation (SAT) of China recently concluded the first advance pricing agreement (APA) for a cost sharing agreement (CSA) with a Fortune 500 enterprise in Guangdong Province. The CSA-APA focuses on international R&D
See MoreCyprus: Cyprus: Tax Authority abolishes minimum margins on loans effective from 1 July 2017
The Cypriot Tax Authorities (CTA) has announced their intention of withdrawing the Minimum Margin scheme (the MMS) with effect 1 July 2017. It is being reminded that in accordance with Article 33 of the Cyprus Income Tax Law, all transactions
See MoreSwitzerland clarifies procedure for recovery of interest paid
The Federal Finance Department has explained the refund procedure regarding the recovery of interest paid for late reporting of intra-group dividend distributions on 1 February 2017. The explanation results from revisions of the procedure for
See MoreChile: Announcement on entry into force of new tax regime
The Tax Administration of Chile announced on 5th January 2017 that a new tax regime enters into force from 1st January 2017 as introduced by the 2014 Tax Reform. Companies under the attributed income regime have to pay first category tax at a
See MorePeru :Amendments to Transfer Pricing rules
In Peru, Law Decree No. 1312 was published on 31 December 2016. The Decree amended the existing Transfer pricing reporting requirement by accepting the proposed changes by the Organization for Economic Cooperation and Development (OECD) within the
See MoreLuxembourg: Tax authorities issued transfer pricing circular
The Luxembourg tax authorities issued a new circular addressing the tax treatment of companies engaged in intra-group financing transactions. On 27 December 2016, Circular L.I.R. n°56/1 – 56bis/1 is released which replaces and supersedes the
See MoreSwitzerland: Parliament adopted the final Corporate Tax Reform III
On June 17, 2016, the Swiss parliament adopted the final Corporate Tax Reform III package (CTR III) to strengthen Switzerland’s competitiveness as a business location. The Corporate Tax Reform III includes several notable tax reform measures
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreTurkey: Draft communiqué on transfer pricing documentation, country-by-country reporting
The revenue administration of Turkey has issued a draft communiqué on 16th March 2016 that would introduce new transfer pricing documentation rules that generally follow the base erosion and profit shifting (BEPS) Action 13 recommendations and
See MoreUK: Autumn Statement Includes Measures Effective from 25 November 2015
The Chancellor of the Exchequer delivered his Autumn Statement to Parliament on 25 November 2015. The measures with immediate effect from 25 November 2015 are as follows: Loans to participators, trustees of charitable trusts: This measure affects
See MoreColombia: National Tax Authority Issued Transfer Pricing Rules on Sales of Intangibles
The National Tax Authority of Colombia announced on sale transactions of intangibles subject to the transfer pricing regime. In article 260-1 of the Tax Code provides criteria for ascertaining whether two or more parties are related parties and the
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreUS: Treasury Department and IRS Released Temporary Regulations and Proposed Regulations to Clarify the Arm’s Length Standard
The Treasury Department and IRS released for publication in the Federal Register Temporary regulations (T.D. 9738) on 15 September 2015 to clarify the arm’s length standard and the best method rule under Code section 482 and the regulations
See MoreChina: Announcement on Cost Sharing Agreements
Recently, China’s State Administration of Taxation has promulgated the Announcement on Standardizing the Administration of Cost Sharing Agreements (the "Announcement 45") for implementation as of July 16, 2015. This announcement 45 is issued to
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