Portugal publishes changes to various Tax Codes

September 23, 2019

On 18 September 2019, the Portuguese Government officially published the Law no.119/2019. The new law has changed the following provisions: Corporate income tax: The procedure whereby non-resident companies may waive all or part of the

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Poland: President signed an act including amendment of TP measures effective in 2019

November 28, 2018

On 14 November 2018, President of Poland signed an act including amendment of transfer pricing measures effective in 2019. The new laws repeal the Article 9a of the CIT Act regarding transfer pricing, which is being replaced by Chapter 1a,

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Pakistan: SECP publishes requirements for companies to maintain record of all related party transactions

October 16, 2018

On 2 October 2018, the Securities and Exchange Commission of Pakistan (SECP) has issued SRO 1194(I)/2018 to introduce Companies (Related Party Transactions and Maintenance of Related Records) Regulations, 2018. These Regulations are applicable on

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Lithuania proposes new transfer pricing rules

February 07, 2018

On 15 January 2018, a draft order amending the regulations of controlled transactions was issued by the Ministry of Finance of the Republic of Lithuania (to amend the Order No. 1K-123 dated 9 April 2004). The main points in the draft order are the

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Azerbaijan-Published amendments to the Tax Code related to Transfer Pricing rules

January 08, 2017

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

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Luxembourg: Tax authorities issued transfer pricing circular

January 05, 2017

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

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Colombia- Tax haven transactions subject to transfer pricing regime

August 16, 2015

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

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Thailand: Draft Act contains new transfer pricing provisions

June 02, 2015

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

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Uruguay-Tax authorities rule on application of transfer pricing study

August 10, 2014

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

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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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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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