Ethiopia: Introduces Transfer Pricing Rules
Ethiopia has introduced Transfer Pricing rules and the new rules are applicable for all Ethiopian taxpayers with cross-border Intercompany Transactions exceeding 500,000 Ethiopian birr/USD 22,380 and for Ethiopian taxpayers with domestic
See MoreBrazil: Private ruling published in the Official Gazette on transfer pricing resale price method
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
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: The tribunal held the Comparable Uncontrolled Price is the most appropriate method
The Delhi Bench of the Income-tax Appellate Tribunal upheld the decision in the case of: Liugong India Private Ltd. v. ACIT (ITA No. 1482/Del/2015) and decided that when comparable are available, the CUP method is the best method to use in
See MoreOECD: Revised guidance on profit splits
On 4 July 2016 the OECD released a consultation document containing revised guidance on profit splits. This is part of the follow-up work on BEPS actions 8 to 10 in relation to assuring that transfer pricing outcomes are in line with value creation.
See MoreAxiom Groupe conference on Transfer Pricing Excellence
The Axiom Groupe conference on Transfer Pricing Excellence was held in Barcelona on 19 and 20 May 2016. The conference included a workshop from the World Bank group. Some of the important issues coming out of the sessions are summarized
See MoreEcuador: Issued Executive Degree 973 to clarify applicability of CUP method
The Executive Decree 973 issued by the president of Ecuador eliminates the application of the CUP method for import and export transactions with public and well-known international prices and the CUP Method for import and export transactions through
See MoreEU Joint Transfer Pricing Forum Discusses Comparables in the EU
The meeting of the EU Joint Transfer Pricing Forum (EU JTPF) on 18 February 2016 considered some of the relevant issues concerning transfer pricing including joint audits in the EU and the use of pan-European comparables. Joint audits in the EU A
See MoreIndia Publishes Notification on Use of Arm’s Length Range and Multiple Year Data
Recently, the Central Board of Direct Taxes published 'Notification No. 83/2015' of 19 October 2015 revising the Income-tax Rules, 1962 in relation to the use of range and multiple year data. The Notification amends Rule 10B and introduces Rule
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreUkraine: Revises its Transfer Pricing Legislation
Ukraine has introduced changes to the Tax Code regarding transfer pricing. It was officially published on August 10, 2015, and came into force from August 11, 2015. As per the new law which came into force from August 11 2015, taxpayers are
See MoreIndia: High Court affirms that comparables must be functionally similar
In the case of: CIT-I v. DSM Anti Infectives India Ltd. ITA No. 116 of 2014 the Punjab and Haryana High Court confirmed a judgment of a tax appellate tribunal that certain companies selected in a search for comparables in a transfer pricing analysis
See MoreOECD publishes comments received on discussion draft on use of the profit split method
On 10 February 2015 the OECD published on its website comments received in response to the discussion draft issued on 16 December 2014 on profit splits in the context of global value chains. One consequence of the ever greater integration of MNEs
See MoreSpain: Modified legislation on transfer pricing published
On 28 November 2014, Laws 26/2014 and 27/2014, which modify the most important Spanish tax laws were published in the Spanish Official Gazette. This new legislation will generally come into force on 1 January 2015. This new legislation modified in
See MoreNigeria: First audit cycle under new transfer pricing regulations starts
The Federal Inland Revenue Service (FIRS) in Nigeria has built a Transfer Pricing Division on November 2013 that is accountable for the execution and administration of the Income Tax Transfer Pricing Regulations No.1 2012 (TP Regulations). This
See MoreIndia: Taxpayer’s use of the Resale Price Method for distribution activities Supported by the court
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
See MorePoland: Amendments on transfer pricing guidelines come into force
The amendment of the Transfer Pricing Ordinance was published in the Official Journal No. 768/2013 on 3 July 2013, in a decree of Poland’s Ministry of Finance.The decree implements the provisions of the 2010 OECD Transfer Pricing Guidelines for
See MoreChina: Selecting the appropriate transfer pricing method in the automotive sector
China’s State Administration of Taxation (SAT) takes the view that locally-based automotive enterprises that are apparently carrying out activities with limited function and risk are in fact performing valuable marketing efforts in China. The tax
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