Spain: Partial amendments of general tax law
Spain has published the official Gazette regarding partial amendments of general tax law which was amended on 22 September, 2015 as a Law no.34/2015. The Law will enter into force on 12 October 2015 except for the obligation to keep specific
See MoreItaly: Extended the Statute of Limitation to Double in Criminal Tax Investigations
Italy has published the decree in the Official Gazette on 18 August 2015 on new anti-¬abuse rule and other measures to enhance legal certainty in tax matters. It became effective on 2 September 2015. The decree also modifies the rules on the
See MoreRomania enacts new Fiscal Procedure Code
The Romanian tax authority has published the revised Fiscal Procedure Code in the Official Gazette no. 545 dated 23 July 2015. The existing Fiscal Procedure Code is being updated by Law 207/2015 implementing new provisions with respect to tax
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
See MoreFrance: Intergroup services marked out in tax-avoidance transactions list
The French tax administration has recently published an updated list of abusive practices and fixtures that are considered to be contrary to the law. Among these are certain inter-group arrangements. Relocation of profits after restructuring:
See MoreChina: Tax Authority’s Plans to Review all Outbound Payments to Overseas Related Parties
The State Administration of Taxation (SAT) has released the Public Notice on March 26, 2015 regarding certain corporate Income Tax matters on Outbound Payments to Overseas Related Parties. Public Notice 16 states that outbound payments to overseas
See MoreFrance: New Tax Laws Permit Sister Companies To Consolidate
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force. According to new law, the changes are below; New rules permitting sister companies to f for tax purposes. A reduction in the real estate
See MoreAustralia: Practice Statement PS LA 2014/2 released by the Australian Taxation Office
The Australian Taxation Office (ATO) released guidance on what the ATO expects taxpayers to prepare in order to comply with the transfer pricing laws and manage related risks on 17 December 2014. According to guidance 25% penalty applies and
See MoreNigeria: Preparing for transfer pricing audit
A transfer pricing declaration and disclosure form will be the first returns filed in compliance with Nigeria’s transfer pricing regulations if returns of taxpayers having a December 2014 accounting year-end. By filing these returns, Nigeria’s
See MoreMexico-Panama: Shared transfer pricing regime
The National Revenue Authority of Panama and Mexico's Tax Administration Service (SAT’s) shared transfer pricing experience in order to know how SAT manages the transfer pricing regime, and analysis its case selection process, and auditing on 14
See MoreCanada: CRA publishes “PTM-05R” on requests for contemporaneous documentation
The Canada Revenue Agency (CRA) has issued a memo on transfer pricing on applications for contemporaneous documentation of the auditor entitled “PTM-05R” on March 28, 2014 and it replaces preceding PTM on the same subject dated 13 October 2004.
See MoreUS: IRS Releases Transfer Pricing Audit Roadmap
On 14 February 2014 a Transfer Pricing Audit Roadmap was issued by the Large Business and International (LB&I) division of the IRS. This sets out the procedures in relation to the conduct of a transfer pricing audit and the timeline to follow.
See MoreUS: GAO Reports that Large Partnerships are Avoiding the IRS Net
In a preliminary report from the United States Government Accountability Office (GAO) it is shown that the IRS is currently conducting a tax audit in respect of only around one percent of the largest partnerships in the US. The GAO report suggests
See MoreNetherlands – Dutch taxpayer liable for Swiss captive subsidiary’s profits
A recent decision by a district Court in the Netherlands involved a Swiss captive insurance company that did not have any employees. The Court reached the decision that the tax authorities in the Netherlands were correct in levying tax on a related
See MoreJapan: Increased focus on transfer pricing in tax audit
Transfer pricing audits in Japan are conducted separately from the general corporate tax audits, by a specialized transfer pricing audit team within the tax authority .The 2011 revision of the tax system in Japan included changes and clarifications
See MoreUruguay’s Tax Authority Reveals 2014 Targets
The Uruguayan tax authority (DGI) has recently revealed its 2014 audit targets. For 2014, the DGI indicated that it plans to conduct 1,350 tax audits in the year. This includes 90 audits for taxpayers whose turnover exceeds UYU50m (USD2.2m), and at
See MoreUnited States – IRS releases transfer pricing audit “roadmap”
The IRS Large Business & International (LB&I) division has released a transfer pricing audit "roadmap" that is intended to be a practical, user-friendly toolkit organized around a notional 24-month audit time-line. The roadmap has been
See MoreBelgium: Transfer pricing audits process
Likely high-risk targets for audits are highly leveraged companies, those with large tax losses carried forward, and those with fluctuating profits. Belgium has increased the number of transfer pricing audits and expanded the team of transfer
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