Transfer Pricing Case Laws
EU Commission proposes to simplify tax rules – and harmonise transfer pricing rules across the EU
12 September 2023, the European Commission published a new proposal to simplify tax rules and harmonise transfer pricing rules across the EU. According to the press release, the proposal, called ...
138 countries agree historic milestone to implement OECD’s Two‐Pillar Solution
12 July 2023 138 members of the OECD/G20 Inclusive Framework agreed an Outcome Statement recognising the significant progress made and allowing countries and jurisdictions to move forward with historic, major ...
Brazil publishes new updated 2023 transfer pricing legislation – aligned with OECD guidelines
14 June 2023 Brazil issued it’s new updated transfer pricing legislation, which is now aligned with OECD transfer pricing guidelines. Click here for unofficial English translation Brazil LEI Nº 14.596, ...
New German Administrative Principles on Transfer Pricing (BMF-AO-2023)
6 June 2023 Germany published it’s new updated administrative principles on transfer pricing. The new publication includes expanded guidance on transfers of functions (and valuation – see English translation) and ...
Malaysia issues new Transfer Pricing Rules for 2023
On 29 May 2002, Malaysia updated its existing TP rules. The new rules are largely in line with the OECD Transfer Pricing Guidelines, but there are minor differences. For example, ...
Poland issues Tax clarifications on transfer pricing – No. 5: Resale Price Method
24 March 2023 the Polish Ministry of Finance issued Tax clarifications on transfer pricing No. 5: Resale Price Method The resale price method (RPM) is one of the traditional transaction ...
Germany issues draft law for implementation of the global minimum tax – OECD Pillar II
The German Federal Ministry of Finance issues draft law for the implementation of the EU Directive to ensure a global minimum level of taxation for multinational groups of companies and ...
AMPOL enters $157 million tax settlement with Australian Tax Office
20 February 2023 Ampol Limited announced entering a $157 million tax settlement agreement with the Australian Tax Office in a dispute over pricing of transactions between Ampol Limited and the ...
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