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Published in Newsletters, TPS
Recently Ireland’s Revenue Authorities released Part 35A-01-01 and Part 35a-01-02 of their Tax & Duty Manual (the “Tax Manual”), which deal with Transfer Pricing and Transfer Pricing Documentation Obligations, respectively. These new section in the Tax Manual are aimed at providing guidance to Irish taxpayers on the application of the Arm’s Length Principle and the […]
Published in Newsletters, Transfer pricing news
On 25 February 2021, the Spanish Tax Administration Agency (AEAT) published a note on the problematic issues that arise when using ranges and statistical measures to determine the value that respects the Arm’s Length Principle, both on the side of the taxpayer and on the side of the Tax Administration. On 6 March 2019, Resolution […]
Published in Newsletters, Transfer pricing news
In February 1st, Spain’s Official Gazette published the general guidelines of the Tax and Customs Control Plan for the year 2021. Following the trend set by previous years, issues relating to the audit of related-party transactions and transfer pricing are gaining weight and forcefulness among the so-called “actions for the investigation and verification of tax […]
Published in Newsletters, Transfer pricing news
On November 23, the Italian Revenue Agency issued new regulations on transfer pricing documentation, Act n. 360494, which introduces substantial and significant changes in the support of the application of the arm’s length principle and the Italian penalty-protection regime, and completely replaces Italy’s former transfer pricing regulations in Act no. 2010/137654. Scope of the reform […]
Published in Newsletters, Transfer pricing news
On October 8, coinciding with the beginning of the parliamentary year in Denmark, a draft bill was presented for debate that modifies the terms of presentation of transfer pricing documentation and the consequences of failure to present it. To date, as in most EU countries, the Danish transfer pricing rules require taxpayers to prepare transfer […]
Published in Newsletters, Transfer pricing news
Spanish resident companies and permanent establishments in Spain with tax year ending 31 December 2019 must file the Tax Reporting (Form 232) on related-party transactions and transactions/investments in tax havens during the month of November 2020. For those taxpayers with a different tax year closing date, the filing period is the eleventh month after the […]
Published in TPS, Transfer pricing news
Our founding partner Claire Sanga participated in the webinar organised by TaxLinked.net in colaboration with Pride Partners International. Enjoy the video recording below and keep updated on the relevant issues you need to know for a TP-compliant closing of financial year 2020 and the actions you need to take on an urgently basis before year […]
Published in Newsletters, Transfer pricing news
On 18 May 2020, the Spain’s Supreme Court has ruled that the Tax Administration can apply the penalty regime provided for in the General Tax Law (GTL) in cases of transfer pricing adjustments to related-party transactions carried out by taxpayers who are exempt from the documentation requirements. This resolution confirms the interpretative criterion of the […]
Published in Newsletters, Transfer pricing news
On May 15, the Federal Administration of Public Revenues (“AFIP”) published Resolution 4717/2020 regarding the transfer pricing regime (amended by R.G. 4733/2020 on June 4, 2020). This resolution establishes the new documentation requirements for related-party transactions, as well as the new deadlines extended due to the COVID19. The main changes introduced by Resolution 4717/2020 are […]
Published in Newsletters, Transfer pricing news
As we are all gradually coming to terms with the fact that Coronavirus is a reality, many enterprises are having to deal with immediate operational issues and manage immediate cash-flow tensions, negotiating with employees, suppliers and financial institutions, amongst others. Companies are focussing their efforts in putting into place measures in order to mitigate as […]