Chile revises procedures for transfer pricing adjustment requests
Chile's Internal Revenue Service (SII) has published Resolution No. 6 of 9 January 2025, which updates procedures for requesting transfer pricing adjustments after adjustments by foreign tax authorities. It updates and replaces Resolution No. 67
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
See MoreJordan: ISTD publishes transfer pricing and CbC Notification forms
Recently, the Jordan Income and Sales Tax Department (ISTD) has published new transfer pricing and country-by-country (CbC) Notification forms (Arabic language) in line with executive instructions No. 3 of 16 September 2021. Transfer pricing
See MoreJordan introduces transfer pricing rules for MNE groups
On 7 June 2021, the Hashemite Kingdom of Jordan has published Regulation No. 40 of 2021 in the Official Gazette. The Regulation has introduced transfer pricing rules for multinational entity (MNE) groups with effect from 7 July 2021. The Regulation
See MoreIreland: Revenue publishes guidelines on corresponding TP adjustments
On 24 April 2020, the Irish Revenue issued an eBrief No. 068/20 to announce about the publication of A new Tax and Duty Manual on corresponding transfer pricing (TP) adjustments. Guidelines for Article 9 Corresponding Adjustment claims This
See MorePuerto Rico amends income tax law for deduction of intercompany charges
Recently, Puerto Rico has amended Section 1033.17(a)(17) of the Puerto Rican Internal Revenue Code of 2011 regarding intercompany expense allocation. Previously there was a disallowance of 51% of intercompany charges. According to the amendment,
See MoreItaly: Revised transfer pricing rules
Decree No. 50 published on 24 April 2017 was implemented on 15 June 2017. According to Article 59 of Decree Law No 50/2017, a corresponding downward adjustment leading to a lower taxable income will no longer be subject to a mutual agreement
See MoreItaly: Decree issued on urgent measures on tax matters
The Council of Ministers of Italy enacted a Law Decree No.50 with an effort to meet the European Union (EU) demands of extra budget deficit cuts. The Decree was published in the Official Gazette on 24 April 2017 and provides urgent measures on tax
See MoreUS: Transfer Pricing Adjustments for Consolidated Group Members
The U.S. Tax Court has issued an opinion concluding that the IRS Commissioner—in exercising authority under Code section 482 and adjusting the reported prices for items transferred among taxpayers and their foreign affiliates—is not required to
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 MoreThailand: Draft Act contains new transfer pricing provisions
The Cabinet of Thailand approved a draft Act on Revenue Code Amendment on 7 May 2015. If enacted the Act would introduce specific transfer pricing provisions into the Revenue Code and also would amend the tax law of Thailand to apply transfer
See MoreFrance: Tax Authority Released The Final Version Of Abridged Documentation Report
The tax authorities of France released the final version of the tax form No 2257-SD on 16 September 2014 which is also known as the abridged documentation report, requiring some information; Information for MNE: Multinational Entity’s
See MoreIndia shows decline in transfer pricing adjustments
The income tax department has estimated that the number of transfer pricing adjustments in 2014 so far has fallen by 14 percent by comparison to the previous year. This may indicate that taxpayers in India are becoming more aware of the transfer
See MoreAustralia: Transfer Pricing being referred as “Profit Shifting”
In Australia, the recent introduction of subdivision 815 has given the Commissioner more extensive powers to transfer pricing adjustments. Subdivision 815 has made a new approach to Australia's transfer pricing analysis which goes beyond the
See MoreIndia : Loan simplification services and fees of foreign branches
In a recent decision, the Mumbai Bench of the Income-tax Appellate Tribunal found that: Services provided by a taxpayer bank were “crucial services” and the services were not a “mere facilitation” for concluding or signing of the loan
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