Saudi Arabia: General Authority of Zakat and Tax (GAZT) publishes draft transfer pricing law
On 10 December 2018, General Authority of Zakat and Tax (GAZT) released draft transfer pricing regulations (TPBy-laws) for public consultation. The regulations broadly follow international standards, including the arm’s-length principle and
See MoreThailand: New Transfer Pricing Law effective from January 2019
On 21 November 2018, the Transfer Pricing Act of Thailand was published in the Royal Gazette and will be effective for accounting years beginning on or after 1 January 2019. Taxpayers with related parties, regardless of having related-party
See MorePoland: President signed an act including amendment of TP measures effective in 2019
On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,
See MoreUkraine: Draft law on implementation of BEPS provisions
On 24 October 2018, Ukraine published a draft law on the implementation of some of the recommendation of the OECD/G20 reports on Base Erosion and Profit Shifting (BEPS). The draft law was developed by the Finance Ministry and National Bank supported
See MorePakistan: SECP publishes requirements for companies to maintain record of all related party transactions
On 2 October 2018, the Securities and Exchange Commission of Pakistan (SECP) has issued SRO 1194(I)/2018 to introduce Companies (Related Party Transactions and Maintenance of Related Records) Regulations, 2018. These Regulations are applicable on
See MoreIreland announces Budget for 2019
On 9 October 2018, the Budget for 2019 was presented to Parliament by the Minister of Finance. The summary of 2019 Budget measures are following: Corporate Tax Film Relief The scheme provides relief in the form of a corporation tax credit related to
See MoreIreland announces corporation tax roadmap
On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions
See MoreUS: Appeal Court Rules in Favour of IRS in Medtronic Case
On 16 August 2018 a US federal appeals court vacated and remanded a 2016 decision by the Tax Court in the case of Medtronic v. Commissioner. The Court of Appeals ruled that in its original decision in favour of Medtronic the Tax Court did not
See MoreUS: IRS issues new transfer pricing examination guide
On 29 June 2018, Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division of the IRS released the Transfer Pricing Examination Process (TPEP) for use in transfer pricing examinations. Transfer Pricing
See MoreItaly: Transfer pricing consultation responses published
On 5 April 2018, the Ministry of Economy and Finance published the responses received to the public consultation on transfer pricing legislation launched in February 2018. Comments and proposals are available on the website of the Ministry of
See MoreSouth Korea: National Tax Service publishes notice on recent changes in transfer pricing rules
On 2 April 2018, the South Korean National Tax Service has published a notice on certain changes including arm's length price determination and APA procedures. In determining the arm's length price, non-price transaction terms are also taken into
See MoreEl Salvador: Ministry of Finance publishes updated transfer pricing guidelines
On 21 March 2018, the Ministry of Finance has published the updated transfer pricing guidelines (DG-001/201). The guidelines outline the comparability analysis adjustments and adjustment information provided in the transfer pricing
See MoreItaly: Draft transfer pricing regulations and corresponding adjustments
On February 21, 2018 the Italian Ministry of Economy and Finance released its draft transfer pricing rules to comply with the Article 8-10 OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The draft rules are declared in their website for
See MoreLithuania proposes new transfer pricing rules
On 15 January 2018, a draft order amending the regulations of controlled transactions was issued by the Ministry of Finance of the Republic of Lithuania (to amend the Order No. 1K-123 dated 9 April 2004). The main points in the draft order are the
See MoreUS: IRS releases directives on transfer pricing examinations
On 12 January 2018, the IRS Large Business and International (LB&I) division publicly released a set of five LB&I directives as guidance with respect for examinations of transfer pricing issues. Interim Instructions on Issuance of
See MoreZambia: MoF approves amendments in transfer pricing regulation
The Minister of Finance (MoF) is set to approve changes in transfer pricing rules, including procedures for the valuation of the transfer pricing transactions between related entities and allow for taxable income adjustments and documentation
See MoreAngola: Tax authority establishes transfer pricing unit
On September 25, 2017, the Ministry of Finance issued the order no. 678/17 establishing the Transfer Pricing Unit (TPU) to ensure and control compliance with the requirement to submit transfer pricing documents. In addition to ensuring and
See MoreNicaragua: Transfer pricing legislations are in effect as of 30 June 2017
The transfer pricing rules are in effect as of 30 June 2017 which was enacted by the Nicaraguan Congress through Law No. 822 of 2012. Law No. 822, enacted on 12 December 2012, contains the Nicaraguan transfer pricing rules that were intended to
See More