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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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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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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Turkey: Council of Minister proposes transfer pricing provisions

June 06, 2017

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

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Turkey: Amendment in transfer pricing legislation

August 19, 2016

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

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India: CBDT has withdrawn the guideline of profit-split method for transfer-pricing transactions, and amends the circular on contract R&D

July 08, 2013

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

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Brazil: Expands Threshold for Companies for presumed Profit Method

May 16, 2013

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

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India: Guidelines for application of the profit split method

April 01, 2013

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

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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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