Transfer Pricing Brief: October 2017
Zambia: Compliance-Corporate residence: On 29 September 2017, the Budget for 2018 was presented to the National Assembly by the Minister of Finance. The Minister proposes to revise the definition of residence for corporate tax purposes by
See MoreTransfer Pricing Brief: September 2017
Taiwan: Main corporate income tax rate: On 1 September 2017, Taiwan’s Ministry of Finance released tax reform proposals including to increase the corporate income tax (CIT) rate from 17% to 20%. The Proposal will become effective for taxable
See MoreTransfer Pricing Brief: August 2017
Brazil: CbC reporting requirement: According to NI 1,722/2017 published in the Official Gazette on 17 July 2017, transitional provisions apply if a legal entity which is resident in Brazil for tax purposes and which is not the ultimate
See MoreTransfer Pricing Brief: July 2017
Poland: Financial services-Restriction on interest deduction: According to draft bill revising on corporate income tax act published on 12 July 2017, thin capitalization rules limiting the deduction of financing costs to 30% of an adjusted tax
See MoreTransfer Pricing Brief: June 2017
Greece: Main corporate tax rate: According to Law 4472/2017 published in the official Gazette on 19th May 2017, the corporate income tax (CIT) rate will be reduced from 29% to 26% from 1 January 2019 subject to certain conditions. See the story
See MoreTransfer Pricing Brief: May 2017
Italy: Requirement-Rule: According to Decree No.50 published on 24 April 2017, the definition of normal value with the concept of arm’s length will be modified to be more aligned with Organisation for Economic Co-operation and Development
See MoreTransfer Pricing Brief: April 2017
China: Adjustments-MAP: Bulletin 6 governs MAP in relation to bilateral/multilateral APAs and special tax adjustments in one jurisdiction which would result in corresponding adjustment in another jurisdiction. According to Bulletin 6, the SAT may
See MoreTransfer Pricing Brief: January 2017
Azerbaijan: Transfer pricing rules: Law No. 454-VQD of 16 December 2016 establishes new transfer pricing (TP) rules for certain transactions. The new TP rules cover transactions whose total value exceeds AZN 500,000 (approximately USD 278,000) in
See MoreTransfer Pricing Brief: November 2016
Malaysia: Penalty for non-compliance of CbC reporting: The fiscal Budget for 2016 has proposed a penalty between MYR 20,000–100,000 or imprisonment of not more than 6 months, or both, for an incorrect return or failure to comply with CbC
See MoreTransfer Pricing Brief: October 2016
Malaysia: Main Corporate tax rate: The Budget for 2017 proposed to reduce the corporate tax rate for the year of assessment 2017 and 2018. As per the proposal, the reduce tax rate will be between 1 and 4 percentage points for companies with
See MoreTransfer Pricing Brief: September 2016
Costa Rica: Filing of annual transfer pricing return: Costa Rica has published a resolution in the official gazette to finalize the rules concerning the filing of an annual transfer pricing return for taxpayers qualifying as “large
See MoreTransfer Pricing Brief: August 2016
Greece: Documentation requirement: As per the bill approved by the Ministry of Finance on 27 July 2016, the General Secretary of Public Revenue may exempt very small enterprises from the submission of transfer pricing documentation. Documentation
See MoreTransfer Pricing Brief: July 2016
Austria: BEPS Related Compliance Master file information: Austria has introduced a requirement for a master file for constituent entities resident in Austria if their turnover in the previous two fiscal years exceeded €50 million in each year.
See MoreTransfer Pricing Brief: June 2016
UK: Secondary adjustment: HMRC launched a consultation on May 26, 2016 to introduce and design secondary adjustment rule into the transfer pricing legislation of UK. See the story in Regfollower Germany: BEPS related compliance General rule for
See MoreTransfer Pricing Brief: May 2016
Sweden: BEPS related compliance Master File information: The Swedish Tax Agency has submitted a proposal to the Swedish Government for new Transfer Pricing documentation like Master File. Under the current proposal, the Master File reporting
See MoreTransfer Pricing Brief: April 2016
Portugal: General rule for CbC reporting requirement: Portugal has introduced Country-by-Country (CbC) reporting requirement for domestic entities with consolidated group revenue of €750 million or more for an accounting period. The CbC report
See MoreTransfer Pricing Brief: March 2016
India: General rule for CbC reporting requirement: India has proposed in the 2016 Union Budget to introduce the country-by-country reporting rules pursuant to the OECD’s three-tier transfer pricing documentation approach. Multinational groups
See MoreTransfer Pricing Brief: February 2016
Taiwan: Transfer Pricing Rules: As per the amendments to the Regulations governing assessment of profit-seeking enterprises, it is mandatory to apply the arm's length principle in the attribution of profits in a business restructuring provided
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