Brazil: Lower House passes transfer pricing reform measure

April 10, 2023

On 30 March 2023, the Brazilian Lower House of Congress adopted Measure No. 1,152 to overhaul its transfer pricing system that was introduced on 29 December 2022. In addition to introducing the arm's length principle into the Brazilian transfer

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Russia: FTS clarifies the application of transfer pricing control under sanctions

March 24, 2022

On 14 March 2022, the Federal Tax Service (FTS) published guidance (Letter No. ШЮ-4-13/2724) stipulating that the application of sanctions against Russian individuals and legal entities may adversely affect the economic conditions of the

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Paraguay introduces new guidance on TP law

January 26, 2021

On 30 December 2020, the tax authority of Paraguay issued Decree 4644/2020, providing further guidance on the technical aspects of Paraguay’s transfer pricing (TP) provisions included in Law 6380. Law No. 6,380/2019 modernized the Paraguayan

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Poland launches public consultation on draft guidance regarding the application of TP Method

December 24, 2020

On 18 December 2020, Poland’s Ministry of Finance has launched a public consultation on draft tax guidance regarding clarifications on transfer pricing regarding the comparable uncontrolled price method. The transfer pricing provisions

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Colombia: DIAN starts a new system for the registration of commodity agreements

August 12, 2020

On 3 August 2020, the Colombian tax authority (DIAN) has launched an online system for registering commodities agreements for the purposes of carrying out commodity operations with related parties from abroad or in the Free Trade Zone or third

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Russia: FTS clarifies the application of CUP method

September 21, 2019

On 2 September 2019, the Federal Tax Service (FTS) of Russia published a Letter No. CA-4-7/17555, about the review of litigation regarding tax control in the field of transfer pricing. For tax purposes, the FTS noted that the courts recognize the

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India: The expenditure specifically incurred for Indian taxpayers’ market cannot be construed to benefit the AE

June 20, 2018

On 14 May 2018, the Delhi Bench of the Income-tax Appellate Tribunal ruled its decision on the transfer pricing (TP) case of BMW India Pvt. V. ACIT (ITA No 6160 / Del. / 2014) in favor of the taxpayer. The court held that, expenses that are

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Ecuador introduces new TP regulations to exports

January 29, 2017

The Internal Revenue Service of Ecuador has issued a Resolution that was published in the official gazette on 30 December 2016. The Resolution launches transfer pricing (TP) regulations applicable to exports of bananas, oil, petrol, gold, silver,

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India:Transfer pricing method applies uniformly to all international transactions

November 25, 2016

The Delhi High Court, in the case of: Magneti Marelli Powertrain India Pvt. Ltd. v. DCIT (ITA 350/2014), held that taxpayer’s contractual obligation to make a payment as per business and commercial requirements and arrangements cannot ipso facto

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India: The tribunal held the Comparable Uncontrolled Price is the most appropriate method

August 10, 2016

The Delhi Bench of the Income-tax Appellate Tribunal upheld the decision in the case of: Liugong India Private Ltd. v. ACIT (ITA No. 1482/Del/2015) and decided that when comparable are available, the CUP method is the best method to use in

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Ecuador: Issued Executive Degree 973 to clarify applicability of CUP method

April 25, 2016

The Executive Decree 973 issued by the president of Ecuador eliminates the application of the CUP method for import and export transactions with public and well-known international prices and the CUP Method for import and export transactions through

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Ukraine: Revises its Transfer Pricing Legislation

September 05, 2015

 Ukraine has introduced changes to the Tax Code regarding transfer pricing. It was officially published on August 10, 2015, and came into force from August 11, 2015. As per the new law which came into force from August 11 2015,  taxpayers are

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Nigeria: First audit cycle under new transfer pricing regulations starts

December 17, 2014

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

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India: CUP method for benchmarking service contracts

July 03, 2013

In a recent decision of Income Tax Appellate Tribunal (“ITAT”) it was held that for benchmarking service contracts when comparable data for these contracts is available the comparable uncontrolled price (CUP) method is the most suitable method.

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India: Listed price cannot be used under the Comparable Uncontrolled Price (CUP) method

June 18, 2013

In a recent decision, the Chennai Bench of the Income-tax Appellate Tribunal held that the list price on a manufacture’s website is only an “indicative price” and so the list price alone cannot be used to determine the arm’s length price of

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Philippines: Transfer Pricing Regulations

February 05, 2013

On 23 January 2013, the Philippines Secretary of Finance issued transfer pricing regulations (Revenue Regulation (RR) No. 02-2013). The regulations provide guidance for applying the arm’s length principle for pricing in related-party transactions

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Nigeria introduced new TP regulations

January 06, 2013

Nigeria has announced new Transfer Pricing Regulations on October 22, 2012. This will be applicable retroactively to August 2, 2012. The TP Regulations provide that all transactions between connected parties should be at arm’s length. Taxpayers

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