Transfer Pricing Brief: July 2013
Australia TPA Rule- New subdivisions 815-B to 815-E ITAA 1997 was enacted on 2 July 2013. Brazil Applicable Methods- Updates on applicable methods for import transactions. Germany TPA Rule-Legislation passed on 29 June 2013 and effective
See MoreTransfer Pricing Brief: June 2013
Australia Intangible property-Arrangements for the license or transfer of intangibles must conform to the arm's length principle. Financial services-A consultation on the thin capitalization rules was announced in the 2013 budget. Brazil Main
See MoreTransfer Pricing Brief: April 2013
Argentina Resolución General N° 3476 introduced new Form F4501, for filing the transfer pricing documentation report. Finland Main corporate income tax rate has been reduced to 20%. India Circular 2/2013 clarifies that the profit split
See MoreTransfer Pricing Brief: March 2013
Australia OECD Guidelines, the new transfer pricing rules require the provisions of the legislation to be interpreted so as to achieve the most consistency with the OECD Guidelines. Taxation Laws Amendment (Countering Tax Avoidance and
See MoreTransfer Pricing Brief: February 2013
Brazil Alternative methods can be used in the case of fixed interest loans in US dollars or Brazilian Reais. A safe harbour rule applies in respect of documentation requirements for export transactions. Specified margins are required in respect of
See MoreTransfer Pricing Brief: January 2013
Austria The Austrian Independent Fiscal Senate (UFS) in decision UFSW, GZ RV 2515-W/09 suggested that the use of an interquartile or a full range depends on the quantity and quality of results of the benchmarking study. A small sample of six
See MoreTransfer Pricing Brief: December 2012
Belgium From 1 January 2013 capital gains made by companies on the disposal of shares are to be taxed at a rate of 0.4% (plus a 3% crisis contribution). Brazil Under Private ruling 8/2012 of 8 November 2012, contributions to a CCA are allowable if
See MoreTransfer Pricing Brief: November 2012
Chile The CUP method is permitted by Law 20,630 effective from 1 January 2013. As regards to the documentation requirements taxpayers will have to file an annual transfer pricing return containing information on foreign related parties,
See MoreTransfer Pricing Brief: October 2012
Chile The main corporate income tax rate is 20% for 2012. Under Law 20,630 amending the transfer pricing rules where an adjustment is made the shortfall is to be treated as a distribution and taxed at a 35% rate, with a penalty of 5%. Law 20,630
See MoreTransfer Pricing Brief: September 2012
Australia A new subdivision 815-A has been passed in 2012 in respect of treaty equivalent cross-border transfer pricing rules. The Commissioner is empowered to challenge the extent of interest deductions in a situation where the level of related
See MoreTransfer Pricing Brief: August 2012
Belgium There are no specific provisions in relation to financial services, but fees must conform to the arm's length principle. Thin capitalization rules apply to restrict the tax deduction for interest on loans between related companies or loans
See More