Poland launches public consultation on draft guidance regarding the application of TP Method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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Tanzania: Revenue Authority issues new transfer pricing guideline 2020

July 30, 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

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Ecuador: The Internal Income Service amends prior Resolutions regarding transfer pricing

July 10, 2020

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

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Turkey: Revenue Administration issues decree on transfer pricing documentation

February 27, 2020

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

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Russia enacts legislative changes on Transfer Pricing and MAP

October 15, 2019

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

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Luxembourg: EU General Court upholds EC Commission’s decision in Fiat case

September 30, 2019

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

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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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Russia proposes Transfer Pricing and MAP-related changes

June 24, 2019

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

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Brazil: RFB updates TP rules on import transaction and commodities

February 13, 2019

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

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Tanzania: Government issues new Transfer Pricing Regulations 2018

December 06, 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

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Belgium issues draft TP guidelines for public comments

December 06, 2018

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

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Brazil: Tax tribunal publishes a decision on costs included for resale price method

November 30, 2018

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

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Argentina: Taxpayers wait for enactment of draft decree no. 1112/2017

November 16, 2018

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

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Brazil: Administrative Council of Tax Appeals approves validity of resale price method (PRL 60)

September 14, 2018

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

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Sweden: Tax Agency updates Transfer Pricing Guidance on Profit Splits method

August 31, 2018

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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Egypt: Government publishes amends income tax law regarding transfer pricing rules

June 28, 2018

Government has published Ministerial Decree No. 221 of 2018 amending certain provisions of the Income Tax Law Executive Regulations under Ministerial Decree No. 991 of 2005 relating to transfer pricing rules on 22nd May 2018. The definition of

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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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