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So far aspect advisory has created 16 blog entries.

Rwanda: New transfer pricing rules

Rwanda: New transfer pricing rules On 14 December 2020, Rwanda passed a Ministerial Order establishing new transfer pricing rules (“TP Order”) replacing the earlier 2007 regulations. The TP Order outlines how article 33 of the 2018 Income Tax law – which requires transactions between multinationals be carried out under the arm’s length principle – is [...]

By |2021-01-27T11:07:35+00:00January 27th, 2021|Africa, Documentation|0 Comments

Italy – New transfer pricing documentation rules effective FY 2020

Italy – New transfer pricing documentation rules effective FY 2020 On 23 November 2020, new transfer pricing rules (Italian Commissioner Decision no. 360494) were introduced to replace the September 2010 requirements. These new rules are effective from financial year 2020 and apply to all resident organisations and permanent establishments situated in Italy. Alignment with extant [...]

By |2021-01-27T10:55:59+00:00January 27th, 2021|Documentation, Europe|0 Comments

Denmark: Submission of transfer pricing documentation now required

Denmark: Submission of transfer pricing documentation now required Earlier this month the Danish Parliament passed a bill that now means taxpayers will have to actively submit transfer pricing (TP) documentation to the tax authority each year. This requirement is effective for tax years starting on or after 1 January 2021 and submission must occur within [...]

By |2020-12-07T17:53:36+00:00December 7th, 2020|Documentation, Europe, Uncategorized|0 Comments

Vietnam: New transfer pricing regulations

Vietnam: New transfer pricing regulations were released on 5 November 2020 and apply for financial year 2020 and going-forward. Transfer pricing benchmarking There have been some interesting changes directly related to transfer pricing benchmarking: Commercial databases are now explicitly referred to as a valid source of comparables for both taxpayers and tax authorities. "Secret comparables" [...]

By |2020-11-09T20:03:37+00:00November 9th, 2020|Benchmarking, Documentation, Europe|0 Comments

Lithuania: Updated transfer pricing documentation requirements

Lithuania: The local tax authority has updated transfer pricing documentation requirements - the updates largely come into effect from 1 January 2021. Low value-add intra-group services The tax authority has adopted a number of simplification measures, one of which relates to the provision of low-value intra-group services. Where a cost plus 5% pricing policy is [...]

By |2020-11-07T13:40:59+00:00November 7th, 2020|Europe, Intangibles, Safe harbors, TP Methods|0 Comments

Turkey: DRAFT Communique for Transfer Pricing Documentation

April 2020: Turkey Draft Communique issued for public comment. The Draft Communique provides detailed information related to  Transfer Pricing Documentation Requirements. The outline is based on the three tier system recommended under OECD's BEPS Project Action Item 13, covering requirements for a Master File, Local File and Country-by-Country Reporting. The Local File is similar to [...]

By |2020-04-22T16:19:17+00:00April 22nd, 2020|Documentation, Europe|0 Comments

Denmark: Draft Bill Introduces Submission of Transfer Pricing Documentation

Denmark: Timely preparation of documentation not enough     A draft bill was announced in mid-September 2019 by the Danish Ministry of Taxation that would require the submission of transfer pricing documentation with taxpayers' annual tax returns, for tax years beginning on or after 1 January 2020. Under the provisions of the draft bill, if [...]

By |2019-09-27T08:49:15+00:00September 27th, 2019|Documentation, Europe|0 Comments

New Zealand: Arm’s length conditions – not just prices

New Zealand: April 2019 - the Inland Revenue published final guidance related to recently amended legislation that better aligns local rules with certain OECD base erosion and profit shifting measures. The guidance comprises five reports covering: Interest limitation Hybrids Transfer pricing Permanent establishments Administrative measures The reports can be found here. With respect to the [...]

By |2019-05-14T08:34:13+00:00May 14th, 2019|Asia Pacific, Contracts|0 Comments

UK: Profit fragementation rules limits benefit of SME transfer pricing exemption

The UK allows a broad exemption from transfer pricing rules for small and medium-sized companies (SMEs) - in most situations: Small enterprises - no more than 50 staff and either an annual turnover or balance sheet total of less than €10 million. Medium enterprises - no more than 250 staff and either an annual turnover [...]

By |2019-05-07T08:32:54+00:00May 7th, 2019|Europe, SMEs|0 Comments

What is transfer pricing – and what does it have to do with roller-skates?

Transfer pricing can be defined simply As we kick-off training this week for our recent new hires at Aspect Advisory, we are starting from the start - by answering the question: what is transfer pricing? Although transfer pricing can be a complex discipline, its base definition is not complicated: Transfer pricing is the pricing of [...]

By |2019-05-02T07:07:24+00:00May 2nd, 2019|Fundamentals|0 Comments