European Commission publishes working paper on State aid and tax rulings

  • By A&S
  • June 5, 2016
  • News

On June 3, 2016, the European Commission (EC) published a working paper on State aid and tax rulings. Prepared as an internal working paper and to provide background to the High Level Forum on State Aid (held on the same day), the working paper provides a brief summary on…

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Denmark to introduce alternative dispute resolution for transfer pricing cases

  • By A&S
  • May 2, 2016
  • News

On May 2, 2016, the Danish Ministry of Taxation (Skatteministeriet, SKAT) issued a press release introducing an alternative dispute resolution (ADR) process for transfer pricing cases. In order to ensure smooth and timely processing of complex transfer pricing cases, SKAT is planning on implementing an alternative dispute resolution process…

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France publishes corporate tax, transfer pricing legislation

  • By A&S
  • January 20, 2016
  • News

France has published new corporate tax and transfer pricing legislation in the official journal, which includes: Modifications to the parent-subsidiary regime; Revisions to the withholding tax exemption regime for dividends paid to EU parent companies; Modifications to the taxation regime of intra-group dividends paid between EU entities; Rules for…

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Cape Verde enacts ordinance introducing transfer pricing guidelines

  • By A&S
  • January 14, 2016
  • News

Cape Verde has enacted Ordinance No. 75/2015 (Portaria de 31 de dezembro), which introduces transfer pricing guidelines on arm’s length pricing for related parties. The guidelines are incorporated into articles 65 and 66 of the Corporate Income Tax Code (Codigo do Imposto sobre o Rendimento das Pessoas Coletivas, IRPC)…

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Finland requesting comments on proposal revising transfer pricing documentation rules, introducing Country-by-Country reporting

  • By A&S
  • January 12, 2016
  • News

The Finnish Ministry of Finance has release a proposal for public comment, which includes revisions to the transfer pricing documentation rules and the introduction of country-by-country (CbC) reporting. The draft bill generally follows the OECD’s recommendations outlined in Action 13 (Transfer pricing documentation and country-by-country reporting) of the BEPS…

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New transfer pricing documentation rules enacted in the Netherlands, includes Country-by-Country reporting

  • By A&S
  • January 11, 2016
  • News

The Dutch Upper House (Eerste Kamer) has passed legislation (‘2016 Other Tax Measures’, in English) amending the transfer pricing documentation rules to include country-by-country reporting obligations, as well as master file and local file provisions. The rules are effective from January 1, 2016. The legislation introduces new standardized documentation…

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Argentina updates ‘white list’ countries for 2016

  • By A&S
  • January 6, 2016
  • News

The Argentine tax administration (Administracion Federal de ÄIngresos Publicos, AFIP) has updated its ‘white list’ of countries, jurisdictions, and territories (i.e. those that have signed tax information exchange agreements and are identified as cooperative for tax transparency purposes). Transactions involving entities in these countries and jurisdictions will not be…

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Singapore updates e-Tax Guide on transfer pricing guidelines

  • By A&S
  • January 6, 2016
  • News

The Inland Revenue Authority of Singapore (IRAS) has issued the third edition of its e-Tax Guide on transfer pricing guidelines. Although the contents of the e-Tax Guide remain largely unchanged, the latest amendments include the following: Enhanced guidance on the cost-plus method (CPM); and Enhancements to the mutual agreement…

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European Parliament asks for additional measures to fight aggressive corporate tax planning and evasion

  • By A&S
  • December 17, 2015
  • News

On December 16, 2015, the European Parliament passed a resolution, prepared in Parliament’s Economic and Monetary Affairs Committee, spelling out the legal steps needed to improve corporate tax transparency, coordination and EU-wide policy convergence. The legal steps recommended by the resolution build on the work of Parliament’s Special Committee on…

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Jamaica introduces transfer pricing legislation

  • By A&S
  • December 16, 2015
  • News

On December 14, 2015, the Tax Administration of Jamaica announced the introduction of transfer pricing legislation, following the approval by both houses of Parliament. According to the related press release, the legislation is effective for 2015 and subsequent financial years, requiring: Taxpayers engaged in transactions with related parties to…

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