Ukraine: 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
See MoreEthiopia: Introduces Transfer Pricing Rules
Ethiopia has introduced Transfer Pricing rules and the new rules are applicable for all Ethiopian taxpayers with cross-border Intercompany Transactions exceeding 500,000 Ethiopian birr/USD 22,380 and for Ethiopian taxpayers with domestic
See MoreMexico: Amendments of transfer pricing rules
Mexico’s Tax Administration Service (SAT) on July 14 published two important transfer pricing rules in the Third Resolution on Amendments to the Omnibus Tax Bill for 2016. Rule No. 3.9.5 of Resolution on Amendments to the Omnibus Tax Bill for 2016
See MoreDenmark: Publishes new executive order on country-by-country reporting
A Danish executive order No. 1133 dated 27 August 2016 was issued to provide detailed rules on notice requirements and on how the CbC report must be completed. The executive order was effective from 1 September 2016. Notification requirements: i)
See MoreChina: New changes of TP regulations
SAT Bulletin No. 42 published on July 13, 2016 has replaced the existing transfer pricing documentation regulations in Circular Guoshuifa No. 2, known as Circular 2. As per Bulletin 42, two parties will be considered related if they have “other
See MoreAustralia: Amended the Transfer Pricing Rules as per 2015 OECD Transfer Pricing Recommendations
Australia's transfer pricing legislation currently specifies that it be interpreted to achieve consistency with the OECD transfer pricing guidelines as last updated in 2010. The OECD's final report on Action Items 8-10 of the G20/OECD BEPS Action
See MoreRomania: New rules enacted for transfer pricing documentation
As per the Order no. 442/2016 published by the National Agency for Fiscal Administration (ANAF) on February 2, 2016, “large taxpayers” engaged in transactions with related parties, having a total annual value determined by reference to the value
See MoreItaly: Published Legislative Decree on Transfer Pricing Issues in the Official Gazette
Italy Published Legislative decree n. 147 in the official gazette on 22 September 2015 with a view to provide investors with certainty arising from their investment plan. As per the published Legislative decree, expenses relating to the transactions
See MoreUS: IRS Released Temporary Regulations to Clarify that the Arm’s-Length Standard of Section 482 Applies to all Controlled Transactions
IRS issued Treasury Decision 9738 on 14 September 2015 containing temporary regulations under Section 482 clarifying the application of the arm’s-length standard when multiple code sections. The temporary regulations apply to tax years ending on
See MoreChina: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreUS: Treasury Department and IRS Released Temporary Regulations and Proposed Regulations to Clarify the Arm’s Length Standard
The Treasury Department and IRS released for publication in the Federal Register Temporary regulations (T.D. 9738) on 15 September 2015 to clarify the arm’s length standard and the best method rule under Code section 482 and the regulations
See MoreColombia- Tax haven transactions subject to transfer pricing regime
The National Tax Authority of Colombia published Ruling 20776 of 2015 according to which transactions carried out with tax haven jurisdictions in tax year 2014 are subject to the transfer pricing regime. According to article 260-7 of the Tax Code
See MoreThailand: Draft Act contains new transfer pricing provisions
The Cabinet of Thailand approved a draft Act on Revenue Code Amendment on 7 May 2015. If enacted the Act would introduce specific transfer pricing provisions into the Revenue Code and also would amend the tax law of Thailand to apply transfer
See MoreAustralia: 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
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