Slovenia- Audits time limits
There is no fixed time limit within which a tax audit may take place. The statute of limitations is normally ten years but may be extended for the duration of legal procedures in connection with collecting
See MoreMalaysia: Audits process
Under the transfer pricing audit framework for transfer pricing audit effective from 1 April 2013, a taxpayer may be selected for audit based on the significance of its controlled transactions before taking into account other risk analysis. The time
See MoreVietnam – Transfer pricing audits based on risk profiles
Vietnam’s General Department of Taxation published transfer pricing audits on 18 December 2013, throughout a number of provinces, and selected some textile, garment, and footwear companies based on transfer pricing risk assessment profiles. The
See MoreSweden –tax audits require due process
In a recent ruling, the Administrative Court in Stockholm held that it was the duty of Swedish tax agency to communicate documents to the taxpayer in a case relating to the taxation of carried interest. The due procedures had not been followed by
See MoreMexican Tax Authority increases focus on auditing supply chain structures
Recent developments within the Mexican Tax Administration Services (SAT) demonstrate an increased focus on auditing supply chain restructurings. This is in line with international trends in transfer pricing, for example the report on business
See MoreIndia: Criteria for manual selection of cases for transfer pricing audit
Instruction No. 10 of 2013 has been issued by the Central Board of Direct Taxes (“CBDT”) on 5th August 2013 which specifying the procedures and criteria for manual selection of cases by the tax administration for audit/ scrutiny for financial
See MoreIndonesia: New Regulation on Transfer Pricing Audits
Regulation PER 22/PJ/2013 has been published by the Indonesia’s Directorate General of Taxation (DGT) on 30 May 2013 to provide guidelines for audits of taxpayers with related-party relationships and repealed the regulation KEP-01/PJ 07/1993
See MoreUkraine: New transfer pricing law
A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with parliament on 12 March 2013. The Tax and Customs Committee of parliament has confirmed that the Transfer Pricing Bill
See MoreNew Tax fraud prevention Law enters into force in Spain
The new criminal code was introduced by Organic Law 7/2012, published in the Official Gazette on 28 December 2012. The code entered into force on 17 January 2013 with respect to transparency and fighting criminal tax and social security
See MoreCanada: CRA issues transfer pricing memoranda
The Canada Revenue Agency (CRA) has to follow the OECD Guidelines when performing transfer pricing audits. Two new transfer pricing memoranda (TPM-13 & TPM-14) have been issued. TPM-13 deals with referrals to the Transfer Pricing Review
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