Dominican Republic: DGII declares public consultation to amend TP rules
On 1 March 2021, the Directorate General of Internal Revenue (DGII) made an announcement of launching a public consultation on the draft modification of articles 5, 7, 10 and 18 of the transfer pricing (TP) regulation, established by means of the
See MoreParaguay introduces new guidance on TP law
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
See MorePoland launches public consultation on draft guidance regarding the application of TP Method
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
See MoreColombia: DIAN starts a new system for the registration of commodity agreements
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
See MoreTanzania: Revenue Authority issues new transfer pricing guideline 2020
On 1 July 2020, the Tanzania Revenue Tax Authority issued the Transfer Pricing Guidelines 2020, which provides the instructions of how to apply Transfer Pricing Regulations, 2018. It covers the guidance on the arm’s length principle, functional
See MoreEcuador: The Internal Income Service amends prior Resolutions regarding transfer pricing
On 1 July 2020, the Government published Resolution No. NAC-DGERCGC20-00000046 of 1 July 2020, which amends the calculation of profit level indicators. According to amendments, it is provided that taxpayers must use the last financial information
See MoreTurkey: Revenue Administration issues decree on transfer pricing documentation
On 25 February 2020, the Turkish Revenue Administration has published Presidential Decree No. 2151 in the official gazette, which amends transfer pricing documentation rules. The decree aims to set out OECD’s Base Erosion and Profit Shifting
See MoreRussia enacts legislative changes on Transfer Pricing and MAP
On 29 September 2019, the Russian Government signed a Law no. 325-FZ (Amendments to the Tax Code of the Russian Federation) and published in the Official Gazette. The main amendments relating to transfer pricing are as
See MoreLuxembourg: EU General Court upholds EC Commission’s decision in Fiat case
On 24 September 2019, the EU General Court upheld the Commission’s decision that Fiat received unlawful State aid from Luxembourg, and at the same time cancelled the decision which had found the same with respect to Starbucks in the
See MoreRussia: FTS clarifies the application of CUP method
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
See MoreRussia proposes Transfer Pricing and MAP-related changes
The Russian Ministry of Finance has proposed some transfer pricing amendments (Draft legislation No. 720839-7) and submitted them to the State Duma for approval (preliminary examination of the draft law submitted to the State Duma). The draft law
See MoreBrazil: RFB updates TP rules on import transaction and commodities
On 29 January 2019, the Brazilian Federal Revenue Department (RFB) issued Normative Instruction (NI) 1870/2019 amending NI 1312/2012 effective as of calendar year 2019. The amendments are mainly related to import transaction and commodities and some
See MoreTanzania: Government issues new Transfer Pricing Regulations 2018
On April 27, 2018,Government has published new Income Tax (Transfer Pricing) Regulations of 2018. The regulations have issued on November 2018, which replaces the Income Tax(Transfer Pricing) Regulations 2014. This provides extra requirements
See MoreBelgium issues draft TP guidelines for public comments
The tax authority of Belgium has published a draft Circular on the 2017 update to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing (TP) Guidelines. On 9 November 2018, the draft Circular was published by the Belgian
See MoreBrazil: Tax tribunal publishes a decision on costs included for resale price method
On November 20, 2018, the Administrative Tribunal for Federal Tax Cases (CARF) has published Decision 1402003338 of 14 August 2018. This decision states that all the expenses regarding freight, insurance, and customs need to include when allowed by
See MoreArgentina: Taxpayers wait for enactment of draft decree no. 1112/2017
Government has released a draft decree No.1112/2017 for tax reform Law 27430 on December 29, 2017, but it has not officially published yet. This decree includes transfer pricing aspects, permanent establishment (PE) rules, restriction on interest
See MoreBrazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)
The Administrative Council of Tax Appeals (CARF) issued binding decision 115 (Súmula no. 115) on 11 September 2018. The new decision approving that, the calculation method of the ' 60% Profit Price Less Profit Method (PRL 60)' provided for in
See MoreSweden: Tax Agency updates Transfer Pricing Guidance on Profit Splits method
On 29 August 2018, the Swedish Tax Agency (Skatteverket) has updated its transfer pricing guidance to incorporate the OECD guidance on the application of the transactional profit split method, which was revised as part of the work for BEPS Action
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