Category: Taxation
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General Communiqué on Disguised Profit Distribution Through Transfer Pricing (Serial No: 4 & 5) in Turkey
The General Communiqués on Disguised Profit Distribution Through Transfer Pricing (Serial No: 4 and 5) in Turkey introduce significant changes to transfer pricing regulations, aligning them with international standards and providing detailed guidance for taxpayers. General Communiqué No. 4 Published in the Official Gazette on September 1, 2020, Communiqué No. 4 revises the original General…
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Law No. 52 of 2016 in Panama
Law No. 52 of October 27, 2016, enacted by the Panamanian government, introduced significant changes for legal entities in Panama, effective from January 1, 2017. The law primarily focuses on accounting record obligations and related requirements for offshore companies and other legal entities. Key aspects of this law include: Accounting Requirements Mandatory Accounting: All entities regulated…
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Inland Revenue (Amendment) (No. 6) Ordinance 2018 in Hong Kong
The Inland Revenue (Amendment) (No. 6) Ordinance 2018 in Hong Kong was gazetted on July 13, 2018. Its primary purpose was to align Hong Kong’s tax laws with international standards under the Base Erosion and Profit Shifting (BEPS) package developed by the OECD. Below are the key features and objectives of this ordinance: Objectives The ordinance codifies transfer pricing principles…
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Austrian Transfer Pricing Documentation Act (VPDG)
The Austrian Transfer Pricing Documentation Act (Verrechnungspreisdokumentationsgesetz, VPDG) was enacted on August 2, 2016, and is effective for fiscal years starting from January 1, 2016. This law implements the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan 13 recommendations and establishes mandatory transfer pricing documentation requirements for multinational enterprise (MNE) groups with entities in Austria.…
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Tax Administration Act 1953 (Subdivision 815-E)
Subdivision 815-E of the Income Tax Assessment Act 1997 in Australia relates to reporting obligations for significant global entities regarding transfer pricing documentation and country-by-country reporting. Key aspects of Subdivision 815-E include: It applies to significant global entities, which are entities with annual global income of over AUD 1 billion. Country-by-country report Master file Local…
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Law 19/2016 of Automatic Exchange of Information on Tax Matters of Andorra
Law 19/2016 of 30 November on the automatic exchange of information in tax matters was passed by the General Council of Andorra and came into force on January 1, 2017. This law implements the OECD’s Common Reporting Standard (CRS) for the automatic exchange of financial account information to improve international tax compliance. Key aspects of Law…
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Income Tax (Transfer Pricing) Rules, 2006 in Kenya
The Income Tax (Transfer Pricing) Rules, 2006 in Kenya were introduced to provide guidelines for related enterprises in determining arm’s length prices for goods and services in transactions between them. These rules were enacted following a landmark case involving the Commissioner of Income Tax and Unilever Kenya Limited, which highlighted the need for clear transfer pricing…
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Act on the Rules of Taxation (Act CL of 2017) – Hungary
The Act on the Rules of Taxation (Act CL of 2017) is a significant piece of legislation in Hungary that came into effect in 2018, introducing several changes to the country’s tax administration system. This act, along with the Act on Tax Administration Procedure (Act CLI of 2017), was part of a broader effort to…
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Section 3B of the Danish Tax Control Act
Section 3B of the Danish Tax Control Act (skattekontrolloven) is a key provision governing transfer pricing documentation and reporting requirements for Danish taxpayers engaging in controlled transactions. The main aspects of this section include: Danish taxpayers must prepare written documentation to substantiate that prices and conditions for intercompany transactions are at arm’s length. This requirement applies…
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Law No. 2018/011 of 11 July 2018 (Cameroon)
The correct title of the law is “Law No. 2018/011 of 11 July 2018 to lay down the Cameroon Code of Transparency and Good Governance in public finance management”. This law establishes the framework for transparency and good governance in the management of public finances in Cameroon. Key points of Law No. 2018/011 include: It sets…
