Transfer Pricing Brief: January 2015

February 01, 2015

Australia     Requirement for Transfer Pricing Documentation- Taxpayers with a high risk transfer pricing profile will be held to more stringent requirements. Transfer Pricing Audits Penalty in Cases of Adjustments-25% penalty applies

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Transfer Pricing Brief: December 2014

January 02, 2015

Argentina Compliance-Decree 2103/2014 created a special unit to monitor cross-border trade and coordinate the work of the various government bodies to ensure the correct application of the law on international trade. Australia Transfer

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Transfer Pricing Brief: November 2014

December 03, 2014

Australia Transfer Pricing Rule-The reconstruction provisions are contained in section 815-130 ITAA 1997. TR 2014/6 gives guidance on identifying situations where the form of commercial or financial relations differs from the

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Transfer Pricing Brief: October 2014

November 03, 2014

Australia Intangible Property-The ATO is increasing the amount of resources devoted to examining business restructurings, marketing hubs and intangible assets.Financial Services- Under Draft Taxation Determination TD 2013/D3 support payments

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Transfer Pricing Brief: September 2014

October 08, 2014

Australia Transfer Pricing Documentation Requirement-Draft practice statement PS LA 3673 sets out the responsibilities in respect of transfer pricing under self-assessment.Penalty in cases of Adjustments- Draft practice statement PS LA 3672

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Transfer Pricing Brief: August 2014

September 03, 2014

Australia Financial services-With effect from 1 July 2014 the permitted debt to equity ratio has been reduced from 3:1 to 1.5:1. Chile Main corporate income tax rate-Under the provisions of a modified tax bill published by the government the

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Transfer Pricing Brief: July 2014

August 06, 2014

Brazil Financial Service- a tax on financial transactions also applies in the case of foreign exchange transactions. Germany Transfer Pricing Rules- Guidance issued by the BMF in June 2014 defines important terms for transfer pricing

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Transfer Pricing Brief: June 2014

July 06, 2014

Canada Penalty for documentation failurePenalties may apply if the taxpayer does not make reasonable efforts to arrive at the arm's length price.Transfer pricing documentation requirement The documentation must outline the organization of the

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Transfer Pricing Brief: May 2014

June 10, 2014

Australia Corporate Income Tax rate 30% for periods to 2013/14.Capital Gain Tax rate-Taxed at the same rate as business income. China Main Corporate Income tax- A lower 15% incentive corporation tax rate applies to specified industries in

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Transfer Pricing Brief: April 2014

May 07, 2014

Australia Tax assessment-The taxpayer should have a "reasonably argued position" on all transfer pricing issues to support the self-assessment return.Transfer pricing rule-TR 2014/D3 gives guidance on factors relevant for identifying the

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Transfer Pricing Brief: March 2014

April 07, 2014

Austria Intangible property-From 1 March 2014 interest and royalty payments to certain related parties are not deductible for tax purposes if the recipient corporation is not subject to tax due to an exemption.Financial Services-From 1 March 2014

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Transfer Pricing Brief: February 2014

March 10, 2014

Argentina Transfer Pricing Requirements (TP)- TP requirements also apply to transactions carried out with individuals or legal entities located, organized or established in low or no tax jurisdictions. Australia Financial Services- On 16

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Transfer Pricing Brief: January 2014

February 09, 2014

Argentina From 3 January 2014 there is a monthly reporting requirement for certain domestic transactions on the Argentinian market using Form F968. France Draft legislation introducing a presumption that profits are received if functions and

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Transfer Pricing Brief: December 2013

January 07, 2014

Australia The ATO's Base Erosion and Profit Shifting (BEPS) team is undertaking a compliance initiative called the International Structuring and Profit Shifting Project (ISAPS project). Brazil Penalties may also apply for non-reporting of

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Transfer Pricing Brief: November 2013

December 01, 2013

Australia Under Draft Taxation Determination TD 2013/D3 support payments made by an Australian parent company to a foreign related entity would be considered as capital payments and would not be tax deductible for the Australian parent.Profit

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Transfer Pricing Brief: October 2013

November 05, 2013

Azerbaijan A Bill on transfer pricing is being re-introduced to parliament and if approved will take effect from 1 January 2014. Brazil Thin capitalization rules apply to restrict the interest deduction unless the value of the debt does not

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Transfer Pricing Brief: September 2013

October 24, 2013

Brazil Under Ordinance 427/2013 where the taxpayer is the lending party a spread of 2.5% is to be added to the minimum interest rate. Ordinance 427/2013 sets a maximum spread of 3.5% for purposes of calculating the tax deduction for

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Transfer Pricing Brief: August 2013

September 08, 2013

Indonesia Certain small and medium enterprises may be taxed on the basis of 1% of turnover. Israel Lower rates apply to companies eligible under the Law for the Encouragement of Capital Investment. Malaysia A Transfer Pricing Audit Framework

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