Cameroon Updates Transfer Pricing Rules to Include Automatic Documentation...
The Cameroon Ministry of Finance announced significant changes to the country’s transfer pricing documentation requirement in its 2012 Finance Law. The revised rules will require Large Taxpayer Units...
View ArticleEl Salvador Passes Transfer Pricing Regulations with Immediate Compliance...
El Salvador joined other Central American nations, including the Dominican Republic and Aruba, in adapting transfer pricing rules that comply with the OECD guidelines. El Salvador implemented formal...
View ArticleBrazil – Provisional Measure Introduces Significant Changes to Transfer...
The Brazilian government made extensive changes to the existing transfer pricing regulations that will come into effect starting in 2013. These modifications, found in the Provisional Measure (“PM”),...
View ArticleAustralia Releases Stage One Reform
The Australian government has released an Exposure Draft outlining the proposed retrospective amendments that will be implemented during the first stage of reform to the country’s transfer pricing...
View ArticleHong Kong Introduces APA Program
The Hong Kong Inland Revenue Department (“IRD”) has taken a significant step in its transfer pricing compliance enforcement by formalizing the Advance Pricing Arrangement (“APA”) program through the...
View ArticleGuatemala Adopts Transfer Pricing Rules
Guatemala has passed transfer pricing legislation, effective January 1, 2013, which will govern related-party transactions involving goods, services or intangible assets. The new rules, included in the...
View ArticleOECD Issues Draft Guidelines Pertaining to Intangibles
The OECD has released a discussion draft clarifying issues specific to intangibles involving multinational enterprises after 18 months since initiating the project in late 2010. The OECD issued the...
View ArticleItaly provides guidance on Mutual Agreement Procedures
The Italian Tax Administration recently issued its first official document pertaining to MAPs. Circular 21/E provides guidance to local tax offices on the application of the two different types of MAP...
View ArticleDenmark strengthens its transfer pricing rules
The Danish government passed a new Act on June 13, 2012 to strengthen its hold on multinational enterprises by increasing fines for transfer pricing non-compliance or insufficient transfer pricing...
View ArticleIRS issues new guidelines on transfers of intangible property
The Internal Revenue Service (IRS) and US Treasury Department released Notice 2012-39 under section 367(d) of the Internal Revenue Code to provide guidance to US domestic companies on handling the...
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