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

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

EUJTPF Issues Report on the Application of the Profit Split Method in the EU

The EUJTPF recently issued a report in which it hoped to clarify key concepts under which the profit split method may be used and on what basis to split the relevant profits. The EU Joint Transfer Pricing Forum, is an entity that assists and advises the European Commission on transfer pricing tax matters.  Source: EUJTPF Report [...]

By |2019-04-30T07:59:18+00:00April 30th, 2019|Europe, Intangibles, TP Methods|0 Comments

Luxembourg Cases Highlights Documentation Importance

Luxembourg: Recent cases highlights the importance of timely and complete transfer pricing documentation to support intercompany pricing arrangements. Source: Luxembourg Times; Alessandra Cea, Transfer Pricing Senior Manager PwC Luxembourg; Marc Rasch, Transfer Pricing Partner PwC Luxembourg In case law n °, 40348 (22 October 2018), a Luxembourg entity received a shareholder loan bearing an interest rate of [...]

By |2019-04-24T07:48:04+00:00April 24th, 2019|Documentation, Europe|0 Comments