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, characteristics of transactions with related and unrelated parties and transfer pricing methods used to compute arm’s length prices. Taxpayers should retain documentation such as transfer pricing studies to support their pricing. Taxpayers should also retain documentation showing the transfer pricing analysis performed and the way in which arm’s length prices were computed. The validity of APA may be effective for a maximum period of four years.

Columbia

 A tax reform bill submitted to Congress in October 2012 proposes to reduce the rate to 25%.

Finland

Draft proposals would introduce a restriction on the deductibility of interest on loans between related parties, which would be limited to a maximum of 30% of earnings before interest, tax, depreciation and amortization (EBITDA).

France

Financial services are covered by the transfer pricing rules. The Finance Bill for 2013 also proposes a general restriction on the deductibility of interest for companies whose interest expenses are more than EUR 3 million in a tax period. Deductible interest would be 85% of interest expenses for 2012 and 2013, and 75% of interest expenses from 2014 onward. The restriction would not apply to companies that are within a French fiscal group.

Nigeria

Nigerian Transfer Pricing Regulations have become effective.

Netherlands

The thin capitalization provisions that previously applied are to be abolished from 1 January 2013, subject to the approval of parliament.

Sweden

Interest is not deductible if it relates to a loan from a related party for the intra-group acquisition of shares or share-based instruments. In certain special circumstances this restriction may also apply to loans from third parties. Under proposed legislation in the 2013 budget this restriction would be extended generally to interest on loans for this purpose from any source.