Angola introduced transfer pricing rules
Angola introduced a transfer pricing rule with a Presidential Decree n. 14713 on June 2014. According to the decree, the taxpayers require to submit transfer pricing documentation by the end of June 2014 to the tax management for the 2013 tax year.
See MoreRussia: Ministry of Finance clarifies the transfer pricing rules
The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax
See MoreItaly’s Transfer Pricing Changes In 2014
Italy has introduced a number of transfer pricing-related changes within its Finance Act 2014 (Law No 147/2013). These changes will have an effect on both administrative procedures and fundamental transfer pricing concepts. Article 1, Paragraph 281
See MoreArgentina: Transfer Pricing Documentation Requirements
From 3 January 2014 there is a monthly reporting requirement for certain domestic transactions on the Argentinian market using Form F968. The criteria for transactions to be included in the monthly report are similar to those that apply to foreign
See MoreFrance – Finance Bill 2014 enacted Transfer Pricing Provisions
The Finance Bill for 2014 of France was published on December 30, 2013. The bill contains transfer pricing provisions but the Constitutional Court has rejected certain controversial provisions. As approved by the Constitutional Court the Finance
See MoreNetherlands – New transfer pricing decree unifies rules
The Dutch Deputy Minister of Finance has issued a new decree that generally unifies and clarifies prior transfer pricing guidance, and withdraws and cancels prior decrees from 2001 and 2004. The new decree is effective from 27 November 2013. The
See MoreNetherlands – new transfer pricing decree
The Dutch Deputy Minister of Finance in late November 2013 issued a decree that generally unifies and clarifies prior transfer pricing guidance, and withdraws and cancels prior decrees from 2001 and 2004. The effective date for the new transfer
See MoreFrance – Administrative Court of Appeal of Paris denies use of secret comparables
The Administrative Court of Appeal of Paris gave its decision in Nestlé Entreprises v. Minister of Economy and Finances (No. 12PA00469) on 5 February 2013 concerning the use of secret comparables under the transfer pricing regulation, article 57 of
See MoreBrazil:Tax authority issues guidance for transfer pricing purposes
The Brazilian tax authority has published guidance for determining the pricing of certain exports and imports of goods that are treated as commodities on 6 November 2013.The guidance also presents new probability for price adjustments. Under the new
See MorePoland: Transfer pricing for business restructurings
Poland’s Finance Ministry issued decrees that bring the transfer pricing provisions of Poland’s tax law into line with international transfer pricing standards on September 3, 2013 and the decree effective from 18 July 2013. The decrees
See MoreAustralia: Prepare for an Australian Taxation Office (ATO) review
Australia is increasingly giving attention to transfer pricing issues and has recently introduced changes in the law to align the transfer pricing rules more closely to the OECD Guidelines. Taxpayers need to be completely ready for an Australian
See MoreAustralia: Effective date of new Transfer Pricing rules
The new transfer pricing rules introduced by Australia are effective for years starting on or after 1st July 2013 and will apply to the transactions of all multinational entities operating in Australia. Before documenting their assessment forms,
See MoreHungary: 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
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