Russia announces transfer pricing changes from 2024

December 15, 2023

On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as

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India: CBDT notifies a formula to adjust MAT relief for secondary adjustment and APA

August 25, 2021

On 10 August 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 92/2021, which contains a new rule for calculating tax relief in the event of an increase in book profit as a result of adjustments to Advance Pricing

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India: CBDT amends rules to calculate interest income relating to Secondary Adjustments

October 13, 2019

On 30 September 2019, the Central Board of Direct Taxes (CBDT) has amended rule 10CB which provide for computation of interest income relating to secondary adjustments. The changes remove anomalies and clarify the compliance and computational

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India: The new Finance Act modifies the Transfer pricing law

July 24, 2019

On 5 July 2019, the Minister of Finance presented the Finance (No.2) Act for the financial year 2019-20. The act changes the following transfer pricing rules: Documentations requirements: Under the new amendments, constituent entity of an

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India: CBDT proposes amendments to secondary adjustment rules for transfer pricing

June 27, 2018

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

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India: CBDT notifies rule for secondary adjustments in transfer pricing

June 20, 2017

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

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UK: Consultation on secondary adjustments in transfer pricing legislation

May 27, 2016

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

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Spain: Supreme Court rules certain provisions of the transfer pricing regulations

August 14, 2014

The Spanish Supreme Court issued its final judgment regarding challenges the constitutionality of specific provisions of the transfer pricing regulations on 14 July, 2014. The Supreme Court focused the following areas; Secondary adjustment: The

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South Africa: Tax authority proposes to revise “secondary adjustment” treatment

August 05, 2014

South African tax authority has been proposed that South Africa’s transfer pricing legislation relating to “secondary adjustments” be amended. The proposal placed to the Draft Tax Laws Amendment Bill 2014. Generally, a “secondary

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South Africa – Transfer pricing, cross-border proposals in 2014 budget

March 09, 2014

South Africa’s 2014 budget contains proposals for changes to the transfer pricing rules and cross-border taxation. Among the transfer pricing and cross-border tax provisions in the 2014 budget are the following measures: Secondary adjustment for

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