Transfer Pricing Brief: January 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
See MoreTransfer Pricing Brief: December 2014
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
See MoreTransfer Pricing Brief: November 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
See MoreTransfer Pricing Brief: October 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
See MoreTransfer Pricing Brief: September 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
See MoreTransfer Pricing Brief: August 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
See MoreTransfer Pricing Brief: July 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
See MoreTransfer Pricing Brief: June 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
See MoreTransfer Pricing Brief: May 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
See MoreTransfer Pricing Brief: April 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
See MoreTransfer Pricing Brief: March 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
See MoreTransfer Pricing Brief: February 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
See MoreTransfer Pricing Brief: January 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
See MoreTransfer Pricing Brief: December 2013
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
See MoreTransfer Pricing Brief: November 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
See MoreTransfer Pricing Brief: October 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
See MoreTransfer Pricing Brief: September 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
See MoreTransfer Pricing Brief: August 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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