India: CBDT proposes amendments to secondary adjustment rules for transfer pricing
On 20 June 2018, the Central Board of Direct Taxes (CBDT) has announced the publication of a draft notification for amendment in Rule 10CB of the Income-tax Rules, 1962 in respect of computation of interest income pursuant to secondary adjustment
See MoreSwitzerland publishes guidance regarding mutual agreement procedure
The Swiss State Secretariat for International Financial Matters has released guidance for mutual agreement procedure (MAP) requests under Switzerland's tax treaties. Switzerland has concluded double taxation agreements with numerous countries.
See MoreBelgium issues a FAQs on MAP and APA
On 23 May 2018, the Public Federal Service (SPF) of Belgium published a document of FAQ on Mutual Agreement Procedure (MAP) and the Advance Pricing Agreement (APA) procedure. The assessee may also request that the tax due in Belgium is not invoiced
See MoreSlovenia publishes the clarification on MAP procedure
The Ministry of Finance of the Republic of Slovenia published the clarification on the Mutual Agreement procedure (MAP) on 7 May 2018, which is set out in the MAP scheme of the Slovenian Tax Treaty Network. The clarification provides detail in the
See MoreUK published draft order to bring BEPS MLI into Effect
UK HM Treasury has laid before the House of Commons the draft Double Taxation Relief (Base Erosion and Profit Shifting) Order 2018. After the order is approved, the UK must then deposit its ratification instrument to enter into force in the
See MoreCanada: CRA issues MAP program report
The Canada Revenue Agency (CRA) issued the latest mutual agreement procedure (MAP) program report on April 13, 2018. The MAP program is a service provided by the CRA to assist taxpayers in resolving cases of double taxation or taxation not in
See MoreAustralia introduces Treasury Laws Amendment (OECD MLI) Bill 2018
On 28 March 2018, the Australian Government introduced Treasury Laws Amendment (OECD Multilateral Instrument) Bill 2018 (the MLI Bill) into Parliament, together with a detailed explanatory memorandum. The MLI bill will need to be passed by the House
See MoreNorway: Government publishes new guidance on MAP
The Norwegian Government published detailed taxpayer guidance on the mutual agreement procedure (MAP) framework set out in Norway’s tax treaties on 7th February 2018. It is an instrument which shall ensure that states apply the tax treaties
See MoreMalaysia: IRBM amends the APA rules and updates the MAP guidelines
Recently, the MIRB (Malaysia Inland Revenue Board) has published an amendment to the APA Rules and the updated Mutual Agreement Procedure (“MAP”) Guidelines. The APA rules referred to as the Income Tax (Advance Pricing Arrangement) Rules 2012
See MoreZambia: MoF approves amendments in transfer pricing regulation
The Minister of Finance (MoF) is set to approve changes in transfer pricing rules, including procedures for the valuation of the transfer pricing transactions between related entities and allow for taxable income adjustments and documentation
See MoreIndia clarifies position on acceptance of the MAP and bilateral APA
On 27 November 2017, the Indian Government has announced that the MAP for transfer pricing disputes and the bilateral advance pricing agreement (APA) process would be available to taxpayers even where Article 9(2) or the equivalent is not present in
See MoreJapan publishes guidance for taxpayers on the MAPs
Recently, the National Tax Agency of Japan has released a guidance on mutual agreement procedures (MAP) on their website. This guidance has been prepared based on the recommendation 2.1 indicated in the final report on Action 14 (Making Dispute
See MoreLuxembourg: Tax authority publishes circular on mutual agreement procedure
To set out the procedures for the implementation of the mutual agreement procedure (MAP), on 28 August 2017, the Director of Taxes published Circular L.G. Conv. D.I. No. 60. The MAP intends to eliminate legal and economic double taxation. The MAP
See MoreIreland publishes MAP guidelines
On 1 August 2017, Irish Revenue published a guidance on the operation of Mutual Agreement Procedure (MAP) is contained in Tax and Duty Manual Part 35-02-08. The purpose of this guidance is to set out the process through which taxpayers can request
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 MoreIndia: CBDT notifies rule for secondary adjustments in transfer pricing
The CBDT has notified a new "Income Tax Rule 10CB" which stipulates a deadline for the reimbursement of excess money (90 days) and the applicable interest rate (separate interest rates for transactions in INR / foreign currency) taken into account
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 MoreGreece: Guidelines for implementing MAP
The Public Revenue Authority has presented guidelines via POL 1049/2017 in relation to implementation of the Mutual Agreement Procedure (“MAP”). The Guidelines give detail on the provisions recently introduced in the tax code. According to the
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