Denmark: Court supports a decision on a case regarding intra-group deposits
On 18 January 2021, the National Tax Tribunal uphold a decision on a case of SKM2021.33.LSR regarding intragroup deposits with a group treasury entity, mentioning the taxpayer’s flawed documentation and differences in the interest rates charged
See MoreDenmark: Parliament adopts a Law regarding transfer pricing
On 3 December 2020, the Parliament adopted the draft Bill No. L 28, which proposes to implement the OECD's recommendations on permanent establishment, so that the Danish rules are brought into line with the latest international standards. The
See MoreDenmark: High Court makes a decision against tax authority’s TP approach
On 5 October 2020, the High Court made a decision on a case entitled “Denmark vs. Shoe Group A/S” against the tax administration’s transfer pricing (TP) approach. The tax administration of Denmark used various theories to claim that a
See MoreIsrael: New Tax Circular on burden of proof related to TP audits
On 2 June 2020, the Israeli Tax Authority (ITA) published tax circular 1/2020 addressing the situations in which a transfer pricing (TP) study that is filed by a taxpayer will be considered as meeting the Israeli TP standards in accordance with
See MoreColombia: DIAN issues new guidelines for GAAR
On 15 January 2020, Colombian tax authority (DIAN) has published Executive Order No. 4 of 7 January 2020 in the official gazette where DIAN clarifies the application of General Anti-Avoidance Rule (GAAR). The GAAR provisions are contained in
See MoreSouth Korea: National Assembly enacts tax reform bill for 2019
On 31 December 2019, South Korea’s National Assembly has enacted tax reform bill for 2019 with a number of new measures added to the existing proposals including changes in transfer pricing measures. The new and amended tax measures are
See MoreChile: IRS issues guidelines regarding anti-avoidance rules
The Inland Revenue Service (IRS) in Chile has issued total 7 circulars including Circulars 65 and 68 on 23rd July 2015 for giving directions won the anti-avoidance rules enacted as part of Law No. 20780. The circulars contain limitations on the
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