Australia: Approval process for application of the reconstruction provisions
The practice statement (PS LA 2015/3) issued on 26 February 2015 sets out a new internal approval process for application of the reconstruction provisions. This law administration practice statement is issued under the authority of the Commissioner
See MoreSlovenia: Government Announces of Tax Cash Register System
The government approved the introduction of a tax cash register system on 5 February 2015. The Act will be published in March 2015 and this system will improve revenue collection. The exact date of the introduction, together with the list of
See MoreFrance – Finance Bill 2014 enacted Transfer Pricing Provisions
The Finance Bill for 2014 of France was published on December 30, 2013. The bill contains transfer pricing provisions but the Constitutional Court has rejected certain controversial provisions. As approved by the Constitutional Court the Finance
See MoreNetherlands – New transfer pricing decree unifies rules
The Dutch Deputy Minister of Finance has issued a new decree that generally unifies and clarifies prior transfer pricing guidance, and withdraws and cancels prior decrees from 2001 and 2004. The new decree is effective from 27 November 2013. The
See MoreNetherlands – new transfer pricing decree
The Dutch Deputy Minister of Finance in late November 2013 issued a decree that generally unifies and clarifies prior transfer pricing guidance, and withdraws and cancels prior decrees from 2001 and 2004. The effective date for the new transfer
See MoreFrance – Administrative Court of Appeal of Paris denies use of secret comparables
The Administrative Court of Appeal of Paris gave its decision in Nestlé Entreprises v. Minister of Economy and Finances (No. 12PA00469) on 5 February 2013 concerning the use of secret comparables under the transfer pricing regulation, article 57 of
See MoreBrazil:Tax authority issues guidance for transfer pricing purposes
The Brazilian tax authority has published guidance for determining the pricing of certain exports and imports of goods that are treated as commodities on 6 November 2013.The guidance also presents new probability for price adjustments. Under the new
See MorePoland: Transfer pricing for business restructurings
Poland’s Finance Ministry issued decrees that bring the transfer pricing provisions of Poland’s tax law into line with international transfer pricing standards on September 3, 2013 and the decree effective from 18 July 2013. The decrees
See MoreArgentina –Modifications to the transfer pricing regulations through General Resolution N° 3,476
The Argentine Federal Tax Authorities issued General Resolution N° 3,476 on 10 April 2013. The Resolution has revised the transfer pricing compliance rules and introduced modifications to the current Transfer Pricing regulations. General Resolution
See MoreAustralia: New Transfer Pricing Legislation
On 13 February 2013, the Federal Government introduced legislation on 13 February containing new Australian Transfer Pricing Laws. These are largely consistent with the Exposure Draft (ED), released in November 2012. The new enactment adjusts
See MoreEcuador: New transfer pricing reporting requirements
The Internal Revenue Service of Ecuador published Resolution NAC-DGERCGC13-00011 on 24 January 2013. Resolution NAC-DGERCGC13-00011 modifies Resolution NAC-DGER2008-0464 on transfer pricing reporting requirements. According to Resolution
See MoreAustralia: New Transfer Pricing Rules
On 22 November 2012, an exposure draft was released introducing new Australian transfer pricing rules with significant self assessment and documentation requirements. Interested parties were invited to comment on the exposure draft. The start date
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