Ireland 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 MoreMalaysia: IRBM updates the guidelines for transfer pricing
The Inland Revenue Board of Malaysia (IRBM) had recently announced new updates and changes to the Transfer Pricing Guidelines 2012 (“TPG 2012”). The Malaysian Transfer Pricing Guidelines explain the provision of Section 140A in the Income Tax
See MoreUkraine: State Fiscal Service clarifies contribution of fixed assets to share capital
Contribution of fixed assets to the share capital of an Ukrainian company is treated as a controlled transaction for transfer pricing purposes. On 9 March 2017, the State Fiscal Service (SFS) clarified this through issuing Guidance Letter No.
See MoreBrazil issues tax regulation program
Provisional Measure 766 has issued and released on 4 January 2017. This provisional measure establishes a tax regulation program for Brazilian taxpayers to settle their tax liabilities. Under this program, taxpayers can resolve their federal tax
See MorePuerto Rico proposes transfer pricing rules
The Department of Treasury has released proposed regulations on 19 November 2016 regarding section 1040.09 of the Puerto Rico Internal Revenue Code of 2011. The proposal highlights US transfer pricing rules and guidelines from the Organization for
See MoreAzerbaijan-Published amendments to the Tax Code related to Transfer Pricing rules
The new amendments to the Azerbaijani Tax Code were published on 25 December 2016. The amendments introduced new Transfer Pricing provisions to the Tax Code. These amendments are effective from 1 January 2017. According to the new rules taxes may
See MoreLuxembourg: Tax authorities issued transfer pricing circular
The Luxembourg tax authorities issued a new circular addressing the tax treatment of companies engaged in intra-group financing transactions. On 27 December 2016, Circular L.I.R. n°56/1 – 56bis/1 is released which replaces and supersedes the
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