Luxembourg: 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
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 MoreUkraine: State Fiscal Service clarifies procedure for transfer pricing adjustments
The State Fiscal Service (SFS) on 4 January 2017 issued Guidance Letter No. 29/6/99-99-15-02-02-15 clarifying the procedure for transfer pricing adjustments by corporate income taxpayers that are required to file quarterly returns. According to tax
See MoreIndia: Proposes amendments to the transfer pricing regulations
Indian Finance Minister published India’s 2017-18 budget on 1 February 2017. Along with other measures, the budget has proposed following important amendments to the provisions of transfer pricing (TP) regulations of India: –A major proposal in
See MoreSingapore: Detailed guidance on MAP for DTAs
The Inland Revenue Authority of Singapore introduced new guidance on the mutual agreement procedure (MAP) on 12 January 2017. The guidance has provided detail procedures for the MAP. According to new guidance, the MAP will be available to those
See MoreMalta: IRD issues Guidelines on use of Mutual Agreement Procedure
The Inland Revenue Department of Malta issued guidelines for the use of the Mutual Agreement Procedure under the provisions of Article 96(2) of the Income Tax Act (ITA), on 15 December 2016. The procedure permits the Malta Competent Authority to
See MoreMexico issued transfer pricing adjustment rule
Mexican tax authorities has been issued rule 3.9.1 of the Miscellaneous Rule on 8 December 2016 regarding transfer pricing adjustments.The rule establishes that all transfer pricing adjustments should be reflected in the tax return in which the
See MoreMalta: Guidance on the use of MAP published
On 15 Dec 2016, The Commissioner for Revenue has published guidance issued under the provisions of article 96(2) of the Income Tax Act (ITA) on the use of Mutual Assistance Procedure
See MoreTanzania issues Finance Bill, 2016
Tanzania’s Finance Bill 2016 was made publicly available on 13th June 2016. This follows presentation of the 2016/17 budget by the Finance Ministry on 8th June 2016. This covers the Finance Bill, 2016 which contains numerous proposed changes in
See MoreUK: Consultation on secondary adjustments in transfer pricing legislation
On 26 May 2016 the UK has published a consultation document on the possible introduction of secondary adjustments into the UK transfer pricing legislation. This would in the opinion of the UK government help to ensure taxpayer compliance with the
See MoreIndia: The Tribunal held that, no transfer pricing adjustment of AMP expenses
The Mumbai Bench of the Income-tax Appellate Tribunal in the case of: L’Oreal India Pvt. Ltd. v. DCIT , held that the tax officer must prove that the taxpayer’s real intention in incurring an advertising, marketing, and promotion (AMP)
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 MoreEU Joint Transfer Pricing Forum meeting in February 2016
The next meeting of the EU Joint Transfer Pricing Forum (EU JTPF) is scheduled for 18 February 2016. The EU JTPF aims to provide tools for practical application of transfer pricing rules in the EU and ensure efficient transfer pricing
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