Transfer Pricing Newsletter

Argentina: Argentine Supreme Court rules set Transfer Pricing regs enacted by presidential decree unconstitutional

Australia: Australia proposes new public country-by-country reporting obligations

Costa Rica: Costa Rica’s Possible Tax Reform

France: New fraud prevention action plan in France: Transfer Pricing obligations to be strengthened

Germany: Tightening of the German Transfer Pricing documentation rules

India: Few landmark rulings and regulatory update

Malta: Malta’s Transfer Pricing rules

The Netherlands: Clarification on the scope and application of the Dutch anti-Transfer Pricing mismatches legislation

Poland: Transfer Pricing adjustment – conflicting approach of Polish tax authorities

Saudi Arabia: Saudi Arabia approves new amendments to the Transaction Pricing (TP) regulations

Senegal: Arm's-length principle in Transfer Pricing: Senegalese tax authorities favour local comparable

The United Arab Emirates: New Transfer Pricing regulation in the UAE: are you prepared?

United Kingdom: APAs, ATCAs, MAPs and HMRC Statistics

Argentina: Argentine Tax Court ruling on “Cargill” Transfer Pricing Case

Austria: Intra-Group Financing – Austrian Specifics

Austria: Decision of the Austrian Financial Court regarding Transfer Pricing

Brazil: Superior Court of Justice rules out illegal Methodology to calculate the PRL 60 Method

Chile: 2022 Tax Reform Bill Proposal to update Transfer Pricing Regulations in Chile

France: Research Tax Credit and Subsidies Synergies with Transfer Pricing

Indonesia: Introduction of New Transfer Pricing Methods

Italy: New Arm's Length Range is set for Transfer Pricing

Poland: Administrative Courts condemn Tax Authorities’ unlawful Practices regarding the Questioning of Benchmarking Studies 

Saudi Arabia: Amending Transfer Pricing Instructions to apply to Zakat Payers

Senegal: Transfer Pricing: Systematizing the Control of Reporting Obligations

Thailand: Cash Pooling between related Companies

Ukraine: The War is not an excuse to ignore Transfer Pricing Compliance

United Kingdom: Draft Legislation on the UK TP Documentation Requirements

Europe

Austria: New Info from the Austrian Ministry of Finance – Mutual Agreement Procedure and Arbitration Procedure

Denmark: Mandatory Submission of Transfer Pricing Documentation in Denmark during 2022

France: The SAP Case: The Difficulty for Tax Courts when Handling Negative Interest Rates

Hungary: TP Update

Ireland: The Irish Position on the proposed ATAD3 Directive

Italy: DAC6 Reporting: Year-End TP Adjustment

United Kingdom: APAs, ATCAs and HM Revenue and Customs Statistics

Further Countries

Argentina: Deemed Affiliation: Cross-Border Transactions with Low-Tax Jurisdictions

Brazil: Plan for Brazil’s Accession to the OECD: Changes to Transfer Pricing Rules

Chile: Practical Lessons learned from Transfer Pricing Audits in Chile

China: First Chinese Customs and Tax Collaborative Transfer Pricing Management Mechanism

India: The Indian Revenue’s Measures for effective Dispute Resolution

Kenya: A Fundamental Shift in the Transfer Pricing Regime in Kenya

Senegal: After joining the Multilateral Convention, a Step forward in the Fight against Tax Evasion & Avoidance

Europe

Austria: No annual CbCR notification required since 1 January 2022

Czech Republic: The Czech Supreme Administrative Court’s thoughts on related party definition

France: The RKS case: shades of nuance in TP by the French Supreme Administrative Court

Germany: New case law on the determination of arm’s length interest rates for intercompany loans

Ireland: TP Compliance requirements in Ireland

Italy: New rules on TP documentation

The Netherlands: Netherlands disallows unilateral downward TP adjustments

Poland: Polish regulations on “indirect” transactions with tax havens

Portugal: Amendments to Transfer Pricing legislation

United Kingdom: Outcome of the UK consultation on TP documentation  

Ukraine: Ukrainian Ministry of Finance clarifies new TP rules on business purpose

Further Countries

Brazil: Effects of extinction of LIBOR rate to Brazilian TP controls

China: Deduction of interest charged by related parties  

New Zealand: New BEPS disclosure guidance and preparation forms

Taiwan: Taiwan CFC rules will be implemented as of 2023 in response to the Global Minimum Tax