Intra-Group Services And Their Effects In Colombia
In Colombia transfer pricing rules date back to the year 2002 when by means of the Law 788 of that year, articles from 260 to 260-11 were added to the Tax Code (TC)19/07/2017
BEPS Action 13 impact on a non-OECD/G20 jurisdiction
This article intends to give a perspective of the challenges that MNEs may confront when dealing with non-standard documentation, based on the first year experience of the Action 13 implementation in one of the non-OECD/G20 countries.17/07/2017
Hong Kong enacted new law to attract corporate treasury operations
On 3 June 2016, the HKSAR Government gazetted the Inland Revenue (Amendment) (No. 2) Ordinance 2016 (the new law) that sought to attract multinational and mainland China enterprises to establish corporate treasury centres (CTCs) in Hong Kong by amending the Hong Kong Inland Revenue Ordinance (IRO)03/08/2016
France and BEPS: a changing transfer pricing landscape
The operative, but not exclusive, article of law in France that currently governs transfer pricing is Article 57 of the French Tax Code ("FTC"), entitling French Tax Authorities ("FTA") to reassess related transactions whose conditions deviate from what independent parties would have agreed under...
30/09/2015
Keeping up to pace with transfer pricing developments in Asian countries
Recent international tax developments in Asia reflect the growing focus on transfer pricing, in tandem with global developments. This summary highlights recent key transfer pricing policy announcements in the region and discusses the potential local impact of country-by-country reporting (CBCR)...
30/09/2015
Tax valuation of IPs in post-deal reorganisation
As part of Base Erosion and Profit Shifting Project (BEPS), OECD has recently issued a publication on transfer pricing aspects of intangibles. The topic of the publication is important, as during the past decades many countries have witnessed a shift from the capital intensive economy to the economy...
31/03/2015
Hong Kong braces itself for a heightened level of transparency
On 25 March 2014, Hong Kong signed a standalone tax information exchange agreement (TIEA) with the US for the enforcement and assessment of taxes. This is the first TIEA signed by Hong Kong after the legal framework for entering into TIEAs with other jurisdictions was put in place last July.
The...
01/09/2014
Aspects of transfer pricing in the Netherlands
The Dutch approach to the arm's length principle has always kept pace with the evolving international interpretation, and arguably in certain aspects has even been ahead of its time. The OECD guidance around alignment between the actual controlling of risks with the contractual division of risks, as...
01/09/2013
ASEAN transfer pricing developments
It has been more than seven years since the Inland Revenue Authority of Singapore (IRAS) released the Singapore Transfer Pricing Guidelines (Guidelines). The key developments in recent times are an increase in the focus of the IRAS on transfer pricing compliance and the use of Advance Pricing...
01/09/2013
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