Poland: MoF publishes guideline on transfer pricing method

April 10, 2023

On 24 March 2023, the Polish Ministry of Finance published guidance clarifying the application of the resale price method to determine the arm's length value of transactions between related parties. The guidance focuses on practical aspects of using

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Poland: MOF launches public consultations for TP method on resale price

April 13, 2022

On 4 April 2022, the Polish Ministry of Finance launched a public consultation on draft guidelines clarifying the resale pricing method for determining the arm's length value of transactions between associated parties. The guidance clarifies,

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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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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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India: Tribunal holds that resale price method is most appropriate method

February 27, 2017

The Delhi Bench of the Income-tax Appellate Tribunal in the case of: Swarovski India Private Ltd. v. ACIT (ITA No. 5621/Del/2014 and ITA No. 5622/Del/2014), held that the resale price method is the most appropriate method to benchmark an

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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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Brazil: Private ruling published in the Official Gazette on transfer pricing resale price method

September 07, 2016

Private Ruling 63/2016 published in the Official Gazette of 31 August 2016 clarified that under the transfer pricing resale price method, the fixed profit margins apply according to the economic sector of the legal entity. In the case of resident

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India: Taxpayer’s use of the Resale Price Method for distribution activities Supported by the court

November 27, 2014

In the case of : CIT v. L’Oreal India Pvt. Ltd. (ITA No. 1046 of 2012 (7 November 2014), The Bombay High Court confirmed a tribunal decision that, the taxpayer’s use of the Resale Price Method (RPM) for purposes of determining the arm’s

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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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