Cyprus issues new clarifications on transfer pricing rules
The Cyprus Tax Department (CTD) announced further developments concerning the Cyprus transfer pricing (TP) rules on Monday, 27 May, 2024. These updates include detailed information on the filing process for the summary information table (SIT).
See MoreUkraine: STS explains international taxation during martial law
On 3 August 2022, the State Tax Service (STS) of Ukraine explained the rights and obligations of taxpayers and supervisory authorities in matters of international taxation during martial law, taking into account the Ukraine- Russia war. Statute
See MoreUkraine clarifies transfer pricing requirements under martial law
On 2 June 2022, the Ukrainian State Tax Service (STS) has published a notification that clarifies transfer pricing requirements under martial law conditions in Ukraine, taking into account of COVID-19 situation. Transfer pricing
See MoreBelgium plans to launch further TP audit cycle
On 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. Based on noncompliant TP forms again audit cycles will be launched by the special TP
See MoreFrance: Government publishes new voluntary tax compliance audit program
On 13 January 2021, the Government published a new voluntary tax compliance audit program for taxpayers to use in addressing and correcting their mistakes while at the same time, allowing the tax authorities to improve the efficiency of tax audits.
See MoreBelgium initiates TP audit cycle of 2021
In the week commencing 11 January 2021, a number of selected Belgian taxpayers received a transfer pricing (TP) questionnaires from the tax authority’s special TP audit department. The questionnaire consists of around 30 questions, which reflects
See MoreItaly enacts Decree in response to COVID-19 outbreak
On 17 March 2020, the Decree No.18 was published in the Official Gazette and entered into force immediately. The Decree introduces several measures in response to COVID-19 outbreak. The key measures are following: Payments of taxes and
See MoreUkraine: MOF amends taxpayer’s audit compliance with the arm’s length principle
On 6 September 2019, the Ukrainian Ministry of Finance (MOF) has published Order No. 307 of 16 July 2019 in the official gazette amending Order No. 399 of 30 March 2017. The amendment clarifies the procedures to audit compliance with the arm’s
See MorePhilippines: BIR issues guidelines for transfer pricing audits
The Bureau of Internal Revenue (BIR) has issued Transfer Pricing Audit Guidelines under Revenue Audit Memorandum Order (RAMO) No. 1-2019 on 20 August 2019, which provides standardized audit procedures and techniques in auditing taxpayers with
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 MoreUkraine: State Fiscal Service clarifies usage of information for transfer pricing purposes
The State Fiscal Service (SFS) recently published Guidance Letter No. 517/Đ“/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 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 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 MoreEU Joint Transfer Pricing Forum Discusses Comparables in the EU
The meeting of the EU Joint Transfer Pricing Forum (EU JTPF) on 18 February 2016 considered some of the relevant issues concerning transfer pricing including joint audits in the EU and the use of pan-European comparables. Joint audits in the EU A
See MoreIndia: CBDT issues guidance on transfer pricing audit procedures
The Central Board of Direct Taxes (CBDT) in India has issued Instruction No. 3 of 2016 on 10 March 2016, with immediate effect as new guidance to provide guidance to Assessing Officers (AOs) in selecting cases for transfer pricing (TP) audits in
See MoreUK: HMRC Clarifies Approach to Taxing Multinationals
The UK Parliament’s Public Accounts Committee is taking evidence on 11 February 2016 in relation to the tax affairs of multinational enterprises. In advance of the parliamentary hearing the UK tax authority HMRC has published a factsheet on its
See MoreNigeria: Implications of BEPS proposals
The Federal Inland Revenue Service (FIRS) has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing
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