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

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