Malawi enacts 2026–27 budget, introduces VAT on digital services by foreign companies
Malawi has enacted the legislation implementing the 2026–2027 Budget, which was published in the Official Gazette on 14 April 2026 and entered into force on 15 April 2026. This follows after Malawi’s Minister of Finance, Economic Planning and
See MoreTaiwan: MOF amends transfer pricing provisions for profit-seeking enterprises
On 28 December 2020, Taiwan’s Ministry of Finance (MOF) has announced amendments to certain transfer pricing provisions based on chapter 8 to 10 of the OECD Transfer Pricing Guidelines for profit-seeking enterprises. The key amendments are
See MoreMalaysia: The Finance Bill 2020 includes transfer pricing measures
On 16 November 2020, Malaysia issued the Finance Bill 2020 (Bill No. DR 17/2020) including following proposals related to transfer pricing provision. Penalties for failure to prepare transfer pricing documentation There is currently no
See MoreTaiwan: MOF announces draft amendments to transfer pricing guidelines
On 18 August 2020, Taiwan’s Ministry of Finance (MOF) has announced draft amendments to certain transfer pricing provisions based on chapter 6 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The
See MoreMalaysia: IRB releases Transfer Pricing audit framework for 2019
On 15 December 2019, the Malaysian Inland Revenue Board (“MIRB”) published the TP audit framework (2019). The Transfer Pricing Audit Framework 2019 is effective from 15 December 2019 and replaces the Transfer Pricing Audit Framework 2013 which
See MoreBulgaria approves new mandatory TP documentation requirements
On 31 July 2019, the National Assembly approved at second (final) reading amendments to the Tax and Social Security Procedure Code (TSSPC), which introduced the new transfer pricing (TP) documentation requirements. New rules for TP
See MoreDenmark: 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 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 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 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 MoreATO published a Practice Statement for TP penalties in transition period
The Australian Taxation Office published a Practice Statement Law Administration 2016/2 (PS LA 2016/2) to deal with the application of transfer pricing penalties during the transition period between 1 July 2004 and 28 June 2013. During that period,
See MoreGreece: Amended Transfer Pricing Penalty in Adjustment
The most important development that took place with regard to Greece’s transfer pricing regime was the enactment of Law 4337/2015 and inclusion of revised transfer pricing penalty in adjustment in new law. As per Law 4337/2015, additional tax
See MoreCzech Republic: Ministry of Finance holds conference on countering tax evasion
The Finance Ministry held a conference on 18th November 2015 regarding tax evasion and measures taken to counter it. It was reported that because of intensifying the fight against tax evasion and avoidance, public revenues had increased. In
See MoreUS: Issues Notice Requesting Comments on Transfer Pricing Penalties
The US Internal Revenue Service (IRS) and the Treasury Department have issued a notice requesting comments on transfer pricing penalties as per temporary and the final regulations. Under both the temporary and the final regulations the penalty may
See MoreGreece: Enacted Rules on Transfer Pricing Penalties and Issued Guidance on TP Documentation
Greece enacted changes to the applicable transfer pricing (TP) documentation rules based on Law 4337/17.10.2015 on 17 October 2015 and issues guidance. Based on the new Law 4337/17.10.2015, the following changes are introduced to the penalties
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 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:
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