Hungary: amendment to transfer pricing documentation rules
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
See MoreChile: Circular notifying transfer pricing changes
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
See MoreFrance: report on tax evasion, transfer pricing
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
See MoreFrance: IGF recommends strengthening control of transfer pricing
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
See MoreUkraine: New transfer pricing law
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
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 MoreDraft list of commodities conditional to transfer pricing rules
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
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 MoreCanada: CRA issues transfer pricing memoranda
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
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
See MoreRussia- Introduces new Transfer Pricing Rules
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
See More