Weekly transfer pricing roundup – 9 October

seminarThe Annual Africa Transfer Pricing Summit (hosted by SAIT) is happening on the 21st and 22nd November. I have the pleasure to partake in two sessions, one on TP and customs and one on CBCR. See more detail about the Summit here.

I would love to hear from you if you have any specific points or should I say “annoyances” in relation to the two topics. I am sure if you had “annoyances” so would many others and maybe we can shed some light on these during the sessions. If you have a chance, please come and see me at the summit, I would love to catch up in person with you. Time permitting I will also try and provide some short summaries on some of the key topics through a weekly update.

So in other news:

Ethiopia introduces new transfer pricing directive (JD Supra)

“Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the application of Article 29 of the Income Tax Proclamation 286/2002, which requires taxpayers to ensure transactions between related persons are conducted at arm’s length, and is effective as of 12 October 2015. The Directive is largely consistent with international standards and will provide Multinational Enterprise Group’s doing business in Ethiopia with clarity concerning the application of Ethiopia’s transfer pricing rules as well as the possibility to obtain certainty through an advance pricing agreement…”

Data shows steep ramp up in penalties on companies shifting profits abroad (Times Colonist)

“Life is getting harder for Canadian multinationals trying to reduce taxes by transferring profits abroad.

In its latest budget, the federal government committed to increasing enforcement efforts against companies that improperly shift profits to lower-tax countries by abusing a legal practice known as transfer pricing — but the Canada Revenue Agency has already been cracking down on the abuse for years.

Data released by the CRA under access-to-information legislation shows that the average penalty for improper transfer pricing increased from $3.4 million 2012 to $15.9 million in 2015…”

New transfer pricing requirements in Poland (Lexology)

“Recent amendments to Poland’s Corporate Income Tax act includes substantial changes to taxpayer’s required transfer pricing documentation. The new rules are in effect from 1 January 2017 – however CBC reporting obligation starts from 2016.

The related entities threshold will rise from a shareholding of 5% to a shareholding of 25%. The transfer pricing requirements will be determined based on the taxpayer’s business size…”

This may not be news but the article is a great summary of the requirements so I had to share it.

Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners (The World Bank)

I wanted to share this with you as well, its from the open knowledge repository of the World Bank. I have not yet had a chance to read it, but I am sure there is a wealth of information in here and the best, it is for free. The full book should be available within a month, and obviously I will share the link here too.

Happy reading, and keep the questions coming, and this time some “annoyances” for the Summit. Have a great week.

What are your thoughts?

This site uses Akismet to reduce spam. Learn how your comment data is processed.