Switzerland: 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
See MoreUruguay: New rules for depreciating intangible assets
The government of Uruguay has modified the rules for depreciating intangible assets through Decree No. 181/015 of 6 July 2015. The new rules have changed the general depreciating period for intangible assets acquired from 1 July 2015. Taxpayers
See MoreItaly: Draft legislative decree introduces advance pricing agreement rollback provision
A draft legislative decree was approved by the Italian Government on 21 April 2015 introducing an advance pricing agreement (APA) rollback provision and provisions relating to costs of transactions with tax havens. The draft decree introduces
See MoreCanada: Guidance on intra-group services published
The Canada Revenue Agency (CRA) has published Transfer Pricing Memorandum (TPM)-15 regarding intra-group services and section 247 of the Income Tax Act on 13th February 2015. TPM-15 describes the CRA’s audit policy on some audit and tax issues
See MoreNigeria: First audit cycle under new transfer pricing regulations starts
The Federal Inland Revenue Service (FIRS) in Nigeria has built a Transfer Pricing Division on November 2013 that is accountable for the execution and administration of the Income Tax Transfer Pricing Regulations No.1 2012 (TP Regulations). This
See MoreIndia: Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions
In India many transfer pricing cases are heard in the Courts. These decisions can provide clarification of the operation of the transfer pricing rules in India and can therefore give potential investors more certainty about the transfer pricing
See MoreUS: Important information regarding intra-group services
The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also
See MoreOECD publishes comments received on intangibles
The OECD has published on its website the comments received by interested parties on its revised discussion draft on transfer pricing aspects of intangibles. The input received from more than sixty commentators will be discussed by the OECD’s
See MoreOECD issues a revised discussion draft on intangibles
For some time the OECD has been conducting a project on transfer pricing aspects of intangible assets including consideration of the definition and valuation of such assets. A discussion draft was issued on 6 June 2012 and followed up by a
See More