Global Transfer Pricing Newsletter #2/2022 now available

It is our pleasure to present to you the second edition of our WTS Global Transfer Pricing Newsletter for 2022.

In this latest edition of the WTS Transfer Pricing Newsletter, our colleagues from 14 countries have provided an update on recently introduced legislations and cases.

Europe

Our Austrian colleagues present the new information of the Austrian Tax regarding Mutual Agreement Procedures as well as Arbitration Procedures.

In Denmark, new rules governing the submission of local TP documentation were established. Our colleagues provide a brief overview.

Our team in France discusses recent case law regarding intercompany cash pool interest rates in a decision involving the SAP Group.

Hungarian TP rules are to change significantly in accordance with the bill submitted to the Hungarian Parliament in the summer of 2022. Our local colleagues provide some details.

The Irish Tax Institute has published its opinion on the upcoming ATAD3 directive by the EU. Our local colleagues present the topic in more detail.

The Italian Tax Agency recently issued a ruling analyzing the application of the DAC6 legislation with respect to TP adjustments. The article sheds some light on this ruling.

Our team in the United Kingdom took part in the recent TP Minds Conference and in this article discusses the statements published by the UK Tax Authorities.

Rest of the world

In Argentina, the Argentinian Tax Administration has published a new version of its list on tax havens or low-tax jurisdictions.

Our colleagues in Brazil report on the latest development in the alignment of the Brazilian Tax Authorities and the OECD in terms of Transfer Pricing.

Out team in Chile presents a summary as well as practical insights from recent transfer pricing audits in Chile.

In China, the Customs and Taxation Department introduced a pilot mechanism targeting the solution of double taxation issues through interdepartmental cooperation. Our local colleagues provide some details on that development.

Our Indian colleagues present some measures taken by the Indian Tax Authorities to facilitate effective and robust dispute resolution with respect to MAP, APA and Safe Harbour Rules.

The Kenyan Tax Authorities issued amended provisions regarding income tax law and transfer pricing. Our colleagues in Kenya describe the most notable changes.

More than 5 years after the signing of the Multilateral Instrument, Senegal deposited its instrument of ratification, which is a huge step forward in the battle against tax evasion & avoidance.

Read the WTS Global Transfer Pricing Newsletter here.