India: Tribunal holds that resale price method is most appropriate method
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
See MoreColombia: Tax reform 2016 and Transfer Pricing Updates
In accordance with law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, introduces the following main changes to the transfer pricing regime. According to article 260-3 of the Tax Code (TC), as amended by the tax
See MoreEcuador introduces new TP regulations to exports
The Internal Revenue Service of Ecuador has issued a Resolution that was published in the official gazette on 30 December 2016. The Resolution launches transfer pricing (TP) regulations applicable to exports of bananas, oil, petrol, gold, silver,
See MorePeru :Amendments to Transfer Pricing rules
In Peru, Law Decree No. 1312 was published on 31 December 2016. The Decree amended the existing Transfer pricing reporting requirement by accepting the proposed changes by the Organization for Economic Cooperation and Development (OECD) within the
See MoreAzerbaijan-Published amendments to the Tax Code related to Transfer Pricing rules
The new amendments to the Azerbaijani Tax Code were published on 25 December 2016. The amendments introduced new Transfer Pricing provisions to the Tax Code. These amendments are effective from 1 January 2017. According to the new rules taxes may
See MoreIndia:Transfer pricing method applies uniformly to all international transactions
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
See MoreEthiopia: 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
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