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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...

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El 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...

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Brazil – 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”),...

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Australia 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...

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Hong 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...

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Guatemala 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...

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OECD 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...

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Italy 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...

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Denmark 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...

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IRS 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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