Nigeria: 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 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
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 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
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