Transfer pricing rules have been part of UK tax legislation since 1997, and most multinationals operating in the UK are required to self-assess compliance with the arm's length principle when completing their tax returns. The UK tax authorities have long seen transfer pricing as a key issue. In...
Canada's federal tax authority, the Canada Revenue Agency (CRA) is a mature and sophisticated tax authority by any measurable global standard. With approximately 40,000 employees, the CRA is responsible for the administration of tax laws in Canada for most of Canada's 10 provinces and three...
Mexico's president on 8 September sent to Congress an economic package that includes proposed amendments to the Income Tax Law (ITL) and the Federal Fiscal Code (FFC) with transfer pricing implications. According to the legislation's explanatory memorandum, the goal is to incorporate the BEPS agenda...
At a time when transfer pricing is at the forefront of the international tax debate, the Dutch Ministry of Finance published a new transfer pricing decree (IFZ 2013/184M). The decree of November 14, 2013, replaced two previous decrees on the application of the arm's length principle. Furthermore, in...
General transfer pricing climate in Germany
Global measures in response to the OECD's BEPS initiative also have had an impact on the regulatory framework in Germany. The German government supports the BEPS initiative, in particular Action 7 (Prevent the artificial avoidance of PE status), Action 8...
One of the main topics Japanese taxpayers are currently interested in is the Organization for Economic Cooperation and Development's (OECD's) base erosion and profit shifting (BEPS) initiative. Broadly speaking, the BEPS initiative looks at whether existing international tax principles and rules...
India's new government has embarked on several unprecedented initiatives to regain investors' confidence by taking bold steps. Recent examples include the decision not to challenge the Bombay High Court's ruling in the Vodafone case at the Supreme Court, the quick response on MAT and FII, and the...
China's State Administration of Taxation (SAT) has been encouraging taxpayers to use the profit split method for a long time. However, outside of advance pricing agreements (APAs), the profit split is not a practical transfer pricing method. Even in the case of APAs, the profit split is used in less...
Mexico's Tax Administration Service published revised administrative rules on 4 July 2014 that extend the period for maquiladoras to restructure their operations to meet the requirement that all of their income from productive activities be derived exclusively from maquiladora operations. The rules...
The Irish Revenue recently issued a statement of practice on the calculation of foreign branch double taxation relief. The change of practice is of relevance for Irish companies with foreign branches, where timing differences arise between jurisdictions for accounting and tax purposes in relation to...