Hungary: amendment to transfer pricing documentation rules

August 27, 2013

The Ministry of Finance of Hungary issued an amendment of Decree No. 22/2009 related to transfer pricing documentation requirements. The amendment effectively increases the validity of an APA to 6 years. Under the new rules taxpayers recharging the

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Chile: Circular notifying transfer pricing changes

July 25, 2013

The Chilean Internal Revenue Service (IRS) has released Circular No. 29 on June 14, 2013 that includes instructions regarding the new transfer pricing rules introduced by Law 20,630. The circular recognizes the OECD TP Guidelines as a valid source

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France: report on tax evasion, transfer pricing

July 03, 2013

The French Minister of Economy and Finance published an official report on transfer pricing legislation on 5 June 2013. The report concludes that France’s transfer pricing rules are out of step with international counterparts. The French General

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France: IGF recommends strengthening control of transfer pricing

June 18, 2013

The French tax authorities released a report on 11 June 2013 regarding recommendations aimed at strengthening existing transfer pricing rules applicable to international groups in France, to better combat tax optimization and avoidance by

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Ukraine: New transfer pricing law

May 08, 2013

A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with parliament on 12 March 2013. The Tax and Customs Committee of parliament has confirmed that the Transfer Pricing Bill

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Argentina –Modifications to the transfer pricing regulations through General Resolution N° 3,476

April 17, 2013

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

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Draft list of commodities conditional to transfer pricing rules

March 18, 2013

Under the Russian transfer pricing (TP) rules in effect since 1 January 2012, import/export transactions with unrelated parties may be subject to the transfer pricing rules if such transactions involve global exchange-traded commodities. The

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Australia: New Transfer Pricing Legislation

February 27, 2013

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

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Ecuador: New transfer pricing reporting requirements

February 05, 2013

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

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Canada: CRA issues transfer pricing memoranda

January 06, 2013

The Canada Revenue Agency (CRA) has to follow the OECD Guidelines when performing transfer pricing audits.  Two new transfer pricing memoranda (TPM-13 & TPM-14) have been issued. TPM-13 deals with referrals to the Transfer Pricing Review

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Australia: New Transfer Pricing Rules

December 19, 2012

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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Russia- Introduces new Transfer Pricing Rules

February 12, 2012

New Federal Law FZ-227 of 18 July 2011 which enacted comprehensive transfer pricing rules entered into force on 1 January 2012. According to the new Law, companies falling under the scope of transfer pricing rules will be obligated to disclose

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