Denmark: Court imposes fines for not providing timely submission of TP documents
On 19 November 2018, the Danish tax authority published an overview of a decision by the Copenhagen Court on whether a company acted in a grossly negligent act for failing to submit the timely submission of transfer pricing (TP) documents and should
See MoreZambia: Finance Minister presents National Budget 2019
On 28 September 2018, Zambia’s Minister of Finance, Hon. Margaret Mwanakatwe presented the 2019 National Budget to Parliament. The time period for making transfer pricing assessment may be raised for a period exceeding 6 years but not exceeding 10
See MoreRussia: The Lower House of Parliament Approves Bill Amending Tax Administration
On 18 July 2018, the Russian lower house of parliament adopted the Bill No. 249505-7 on improving tax administration in the third and final reading. The Bill includes following measures: Eliminate transfer pricing control (audit) for domestic
See MoreIreland: New guidelines on TP compliance
On May 28, Irish Tax and Customs updated Tax and Duty Manual Part 35A-01-01 to set out the government’s approach to monitoring compliance with transfer pricing legislation contained in Part 35A of the Taxes Consolidation Act 1997. The new
See MoreItaly: Approves budget Law for 2018
The Italian Budget Law for 2018 (Law no. 205 of 27 December 2017) published on 29 December 2017 and entered into force on 1 January 2018. Some of its most significant corporate tax measures are summarized below: Dividends: Dividends from
See MoreArgentina: Government reforms transfer pricing rules via Decree 1112/2017
The government has issued a Decree No.1112/2017 on December 29, 2017, for enacting and making effective of comprehensive tax reform. It also contains the new rules for transfer pricing. According to the new Law, transactions with parties in low-tax
See MoreKorea: 2017 tax reform proposals announced
The government of South Korea is planning to increase the tax rate for large companies and high-earning individuals with the hope of reducing inequality. With this aim, Korea’s Ministry of Strategy and Finance announced the 2017 tax reform
See MoreIndia introduces CbC reporting requirements
India has included a country-by-country (CbC) reporting requirement in section 286 of the Indian Income-tax Act, 1961, with effect from the financial year 2016-2017. The requirements are principally in line with BEPS Action 13. The first round of
See MoreVietnam: National Assembly passes the new technology transfer law
The National Assembly of Vietnam on 19 June 2017 approved the Law on Technology Transfer No. 07/2017 / QH14 ("LTT 2017"). The new law (LTT 2017) comes into force on 1 July 2018 and replaces the Law on Technology Transfer No. 80/2006 / QH11 of 29
See MorePakistan: FBR proposes to introduce a Directorate General of Transfer pricing
Federal Board of Revenue (FBR) has proposed through Finance Bill 2017 to establish Directorate General of Transfer Pricing which shall consist of a Director General and as many Directors, Additional Directors, Deputy Directors, Assistant Directors
See MoreMalaysia: IRBM issues amended tax audit framework for 2017
The Inland Revenue Board of Malaysia (IRBM) issued an amended tax audit framework on 1 May 2017. The aim the amended framework is to ensure that tax audits are carried out in a fair, transparent and impartial manner. The framework outlines the
See MoreAustralia: Practical Compliance Guideline – cross-border related party financing arrangements and related transactions
On 16 May 2017, the Australian Tax Office (ATO) released a draft Practical Compliance Guideline that sets out the compliance approach for cross-border related party financing arrangements as defined in section 995-1 of the Income Tax Assessment
See MoreUkraine: State Fiscal Service clarifies usage of information for transfer pricing purposes
The State Fiscal Service (SFS) recently published Guidance Letter No. 517/Г/99-99-12-03-07-14 of 16 January 2017, the State Fiscal Service (SFS) clarified which sources of information should be used for transfer pricing purposes according to the
See MoreIndia: Delhi High Court removed the penalty assessment for related-party transactions
The Delhi High Court, in the case of: Pr.CIT v. Mitsui Prime Advanced Composites India Pvt. Ltd. (ITA 913/2016, CM APPL.46519/2016), dismissing tax department’s appeal and upheld the Tribunal’s order deleting penalty under Section 271(1)(c) of
See MoreCzech Republic: Tax audits focused on transfer pricing increases
The number of tax audits focused on transfer pricing in the Czech Republic and the resulting tax adjustments have increased rapidly because of Czech Tax Administration’s systematic risk assessments. These risk assessments are successively used to
See MoreAustralia: DPT Bill includes updated transfer pricing guidelines
On 9 February 2017, the Australian Government introduced legislation into the Parliament to implement the new Diverted Profits Tax (DPT), which will prevent multinationals shifting profits made in Australia offshore to avoid paying tax. The Diverted
See MoreAustralia releases guidance on related-party marketing hubs
On 16 January 2017, the Australian Taxation Office (ATO) issued a Practical Compliance Guideline which sets out the ATO's compliance approach to transfer pricing issues related to the location and relocation of certain business activities and
See MoreColombia: Tax administrative summary of tax reform 2016
According to law 1819 of 2016, adopting the structural tax reform bill approved on 23 December 2016, which introduces the following major changes to the tax administration, tax procedures and penalties: Tax administration The tax reform introduces
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