Turkey: 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 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 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
See MoreEgypt: Government publishes amends income tax law regarding transfer pricing rules
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
See MoreTurkey: Council of Minister proposes transfer pricing provisions
A draft Communique regarding transfer pricing has been published in Turkey. It generally represents measures of the OECD’s base erosion and profit shifting (BEPS) Action 13 on country-by-country reporting and transfer pricing documentation. The
See MoreTurkey: Amendment in transfer pricing legislation
The Law No. 6728 on the amendment of certain laws for the improvement of the investment landscape has been published in the Official Gazette on 9 August 2016. This law amended certain transfer pricing provisions. Some of the provisions are given
See MoreIndia: CBDT has withdrawn the guideline of profit-split method for transfer-pricing transactions, and amends the circular on contract R&D
The Central Board of Direct Taxes (CBDT) withdrew Circular No. 2/2013 on June 2013as it gives the impression that the profit split method is the preferred method in cases involving unique intangibles or in multiple interrelated international
See MoreBrazil: Expands Threshold for Companies for presumed Profit Method
The profit method is one of four calculation regimes that may be applied by some companies for the computation of profits for Brazil’s corporate income tax. This is a simplified regime that enables a company to pay tax based on a percentage of its
See MoreIndia: Guidelines for application of the profit split method
India’s Central Board of Direct Taxes (CBDT) has issued Circular No. 2 of 2013, setting out guidelines for application of the Profit Split Method (PSM) in international transactions. The profit split method is one of the permitted methods for
See MorePhilippines: Transfer Pricing Regulations
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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