Archive: Transfer pricing

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Dominican Republic modifies transfer pricing regulations [TAX ALERT]

Dominican Republic modifies transfer pricing regulations [TAX ALERT]

April 24, 2014. Tags: ,

The Dominican Republic (DR) will publish Executive Decree No. 78-14 in the next few days, which will make changes to the transfer pricing regulations. In general, …

European Union: Joint Transfer Pricing Forum presents transfer pricing profiles of EU Member States

European Union: Joint Transfer Pricing Forum presents transfer pricing profiles of EU Member States

April 24, 2014. Tags: ,

The EU Joint Transfer Pricing Forum (JTPF) has presented the transfer pricing profiles of all EU Member States, which contain information about domestic transfer pricing …

OECD invites public comments on the paper on Transfer Pricing Comparability Data and Developing Countries [TAX ALERT]

OECD invites public comments on the paper on Transfer Pricing Comparability Data and Developing Countries [TAX ALERT]

April 21, 2014. Tags: ,

On 11 March 2014, the Organisation for Economic Cooperation and Development (OECD) released a discussion paper on Transfer Pricing Comparability Data and Developing Countries. The paper …

Nigerian Tax Authorities issue transfer pricing guidance and forms [TAX ALERT]

Nigerian Tax Authorities issue transfer pricing guidance and forms [TAX ALERT]

April 14, 2014. Tags: , , ,

Nigeria’s Federal Inland Revenue Service Transfer Pricing (FIRS TP) Division is responsible for implementation of the country’s new Income Tax Transfer Pricing Regulations No.1 2012 …

Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions [TAX ALERT]

Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions [TAX ALERT]

April 11, 2014. Tags: , , ,

The Delhi Income-tax Appellate Tribunal (Tribunal), in a ruling1 in the case of M/s. Bharti Airtel Limited (Taxpayer) has adjudicated on transfer pricing (TP) issues arising …

United States: US Senate subcommittee issues report on offshore profit shifting by Caterpillar

United States: US Senate subcommittee issues report on offshore profit shifting by Caterpillar

April 7, 2014. Tags: , ,

The US Senate Permanent Subcommittee on Investigations has issued a majority staff report that provides details regarding an offshore tax strategy used by Caterpillar Inc., …

United States: US Bankruptcy Court rejects IRS’s transfer pricing adjustment

United States: US Bankruptcy Court rejects IRS’s transfer pricing adjustment

April 3, 2014. Tags: , ,

The US Bankruptcy Court for the Middle District of North Carolina (Greensboro Division) has disallowed a transfer pricing adjustment made by the US Internal Revenue …

United States: IRS releases annual transfer pricing APA report for 2013

United States: IRS releases annual transfer pricing APA report for 2013

April 2, 2014. Tags: , ,

The US Internal Revenue Service (IRS) has released its annual report for 2013 on advance pricing agreements (APAs) and the advance pricing and mutual agreement …

Colombia: transfer pricing regulations issued – details

Colombia: transfer pricing regulations issued – details

April 1, 2014. Tags: , ,

Decree No. 3030 of 2013, applicable as from 1 January 2014, regulates transfer pricing provisions that were amended by the latest tax reform. The following are …

Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions [TAX ALERT]

Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions [TAX ALERT]

March 31, 2014. Tags: ,

The Delhi Income-tax Appellate Tribunal (Tribunal), in a ruling in the case of M/s. Bharti Airtel Limited (Taxpayer) has adjudicated on transfer pricing (TP) issues …

Special Bench of Mumbai Tribunal rules on approach to selection of comparable data [TAX ALERT]

Special Bench of Mumbai Tribunal rules on approach to selection of comparable data [TAX ALERT]

March 31, 2014. Tags: ,

This Tax Alert summarizes a recent decision of the Special Bench of the Mumbai Income-tax Appellate Tribunal (SB) in the case of Maersk Global Centres …

Guatemala Tax Administration confirms transfer pricing compliance for 2013 [TAX ALERT]

Guatemala Tax Administration confirms transfer pricing compliance for 2013 [TAX ALERT]

March 28, 2014. Tags: , ,

On 11 March 2014, the Guatemala Tax Administration (Superintendencia de Administración Tributaria or SAT) issued an announcement in the Publinews gazette, affirming the obligation for …

Dutch Lower Court finds lack of arm’s length return in captive reinsurance case [TAX ALERT]

Dutch Lower Court finds lack of arm’s length return in captive reinsurance case [TAX ALERT]

March 21, 2014. Tags: ,

On 17 January 2014, the Lower Court of Zeeland-West-Brabant (Court) ruled in a captive reinsurance case involving a Dutch insurance company and its Swiss subsidiary. The …

Spain: tax measures to enhance debt financing and restructuring published

Spain: tax measures to enhance debt financing and restructuring published

March 20, 2014. Tags: , ,

On 8 March 2014, the Official Gazette published Royal Decree-Law 4/2014 of 7 March 2014, approving urgent measures in respect of corporate debt refinancing and …

Colombia modifies transfer pricing regulations [TAX ALERT]

Colombia modifies transfer pricing regulations [TAX ALERT]

March 19, 2014. Tags: ,

Colombia has modified its transfer pricing regulations in accordance with Law 1607 enacted in December 2012, which included reforms to the transfer pricing rules. Further details …

OECD releases draft paper on transfer pricing comparability data and developing countries

OECD releases draft paper on transfer pricing comparability data and developing countries

March 17, 2014. Tags: , ,

The Organisation for Economic Co-operation and Development (OECD) was requested by the G8 at its Lough Erne summit “to find ways to address the concerns …

South Africa aligns secondary transfer pricing adjustment with international standards [TAX ALERT]

South Africa aligns secondary transfer pricing adjustment with international standards [TAX ALERT]

March 17, 2014. Tags: ,

Section 31 previously authorized the South African Revenue Service (SARS) to adjust the consideration for goods or services to an arm’s length price for the …

El Salvador introduces changes in transfer pricing information return [TAX ALERT]

El Salvador introduces changes in transfer pricing information return [TAX ALERT]

March 13, 2014. Tags: ,

Effective 5 February 2014, El Salvador modified its transfer pricing information return (F-982 V3). The return includes a new section in which the taxpayer must …

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