Russia: Amendments to transfer pricing rules have entered into force
On the basis of Federal Law No. 379-FZ, the amendments has made in transfer pricing (TP) rules and it was issued on 29th November 2014. This amendments to TP rules have entered into force on 1st January 2015. The important changes are given
See MoreSlovenia: Government Announces of Tax Cash Register System
The government approved the introduction of a tax cash register system on 5 February 2015. The Act will be published in March 2015 and this system will improve revenue collection. The exact date of the introduction, together with the list of
See MoreNigeria: First audit cycle under new transfer pricing regulations starts
The Federal Inland Revenue Service (FIRS) in Nigeria has built a Transfer Pricing Division on November 2013 that is accountable for the execution and administration of the Income Tax Transfer Pricing Regulations No.1 2012 (TP Regulations). This
See MoreLuxembourg: New Transfer Pricing rules from 2015
A new transfer pricing rules will take effect in Luxembourg from the year 2015 in line with international principles and OECD Tax Model convention providing adjustments of profit provisions if transfer pricing do not reflect the Arm’s Length
See MoreUruguay-Tax authorities rule on application of transfer pricing study
The tax administration of Uruguay issued Ruling No. 5,975 on 18 June 2014. According to the ruling transfer pricing study will not be applicable in the case of financial operations between a Uruguayan branch and foreign parent. The ruling will
See MoreAngola 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
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