IBX-Jakarta. Quoting from www.wts.com here the update Transfer Pricing in many countries.
General Transfer Pricing topic
The Transfer Pricing Digital Team in Germany explores the opportunities of utilising data analytics tools like Alteryx and visualisation platforms such as PowerBI to enhance Transfer Pricing documentation projects.
Country-specific Transfer Pricing topics
The Argentine Supreme Court’s landmark ruling invalidates the presidential decree on Transfer Pricing, providing crucial tax relief to the commodity exporting sector.
In Australia, the proposed legislation would lead to the first unrestricted worldwide mandated public reporting of all CbCR data combined with additional Information by jurisdiction. More details about which companies are concerned and the new disclo-sures required can be found in the article.
Costa Rica’s government has submitted a tax reform proposal to the Legislative Assembly, aiming to introduce significant changes to the country’s income tax system. The proposed reform includes a shift to a mixed tax system for residents, consolidation of individual income tax, a general 15% tax rate for non-residents and expanded powers for the Tax Administration.
France launches a comprehensive anti-fraud plan, aiming to target the “ultra-rich” and multinational companies, strengthen Transfer Pricing obligations and enhance tax transparency measures, showcasing its determination to tackle tax evasion effectively.
In Germany, new legislation has been adopted to tighten Transfer Pricing documenta- tion rules, allowing tax authorities to demand records at any time, reducing submission deadlines and imposing stricter penalties for non-compliance.
India’s recent rulings and regulatory updates in Transfer Pricing cases have under-scored the importance of robust comparability parameters and international guide-lines for determining arm’s-length prices, shaping the landscape of tax regulations.
Recently, Malta has introduced Transfer Pricing rules which will take effect from the financial year 2024. The rules require companies to include the arm’s-length principle of cross-border arrangements with associated enterprises in determining their total taxable income, with additional guidelines expected to be issued to determine the methodologies for establishing the arm’s-length principle.
The Netherlands has implemented anti-Transfer Pricing mismatch rules to counter double non-taxation, and a recent decree provides clarification that these rules do not apply to entities exempt from or not subject to profit tax, reducing uncertainties for pension funds and other exempt entities.
In Poland dealt with the conflicting approach of Polish tax authorities regarding the tax treatment of Transfer Pricing adjustments.
In Saudi Arabia requirements for the master file and local file, with compliance varying based on the value of transactions with related parties, were introduced.
The Senegalese tax authorities prioritize local comparable over quoted prices for Transfer Pricing, emphasizing their accuracy in reflecting company profitability, but the specific conditions for applying the arm’s-length principle remain undefined. The UAE has implemented new Transfer Pricing regulations aligned with OECD guide-lines, requiring businesses to maintain documentation and adhere to the arm’s-length principle. The article provides a roadmap for taxpayers to evaluate the impact of new TP rules.
In UK focused on examining the latest statistics and developments provided by the HMRC regarding the usage of APAs, ATCAs and MAPs.
Souerce: https://wts.com/wts.com/publications/transfer-pricing-newsletter/2023/wts-newsletter-tp-1-2023.pdf
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