India:

Intangible property: The Delhi High Court ruling on marketing intangibles in the Sony Ericsson Mobile Communications India Pvt. Ltd. case provides clear guidance on how the issue of marketing intangibles should be viewed in cases where the taxpayer is characterized as a distributor. The High Court concluded that marketing and distribution functions are closely connected, and thus may be bundled for purposes of determining the arm’s length price. It is not mandatory to subject advertising, marketing and promotional (AMP) expenses to a bright-line test and consider non-routine AMP activities as separate transactions.

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OECD:

BEPS Country by Country (CbC) Reporting: OECD released a package of measures for implementing the country by country reporting plan. The package includes model legislation that will require the parent entity of each multinational group to file the CbC report in the jurisdiction where it is resident. The legislation requires any constituent entity of a multinational group that is resident in a particular country to notify the tax administration whether it is the ultimate parent entity of the group.

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Brazil:

For import transactions: The Normative Instruction (NI) 1568/15 published by the Brazilian Federal Revenue Department on June 8, 2015  has restricted the application of the intermediation cost adjustments in the calculation of the transfer price based on the Brazilian commodities methods applicable to imports.

For export transactions:  The Brazilian Federal Revenue Department published Normative Instruction (NI) 1568/15 restricting the application of the intermediation cost adjustments in the calculation of the transfer price based on the Brazilian commodities methods applicable to exports.

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Slovak Republic:

Documentation Format: The Slovak Ministry of Finance has issued new guidance on transfer pricing documentation divided in three categories like full, basic and abbreviated documentation. The three categories distinguish between the minimum documentation required for each category. The Guidance further stipulates which taxpayers must maintain what category of documentation.

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Bangladesh:

Specific TP Compliance: Report from an accountant to be furnished who has entered into international transaction as per section 107F has been replaced by new wording and included Cost and Management Accountant to act as an accountant and specified the documents and records which need to be furnished.

Penalty for Documentation Failure: Transfer pricing new penalty provision of 2% on the value of each international transaction has also been included in a new section 107HH for failure to report international transactions statement with the annual tax return.

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