Go to main navigation
Go to main content
Go to BDO global home page
BDO
Tax News
Homepage
Corporate Tax News
Issue 66 - May 2023
Archived Issues
Explore Corporate International Tax services
See all
Close Menu
Indirect Tax News
Issue 2-2023
Archived Issues
Explore Indirect Tax Services
See all
Close Menu
GES News
May 2023 Issue
Archived Issues
Explore Global Employer Services
See all
Close Menu
Transfer Pricing News
Issue 42 - March 2023
Archived Issues
Explore Global Transfer Pricing Services
See all
Close Menu
Global Tax Alerts
Home
>
Transfer Pricing News
>
INTERNATIONAL - Transfer pricing bytes
INTERNATIONAL
Transfer Pricing News Issue 38 - March 2022
Transfer pricing bytes
Australia:
The government
announced
that it will review the advance pricing arrangement (APA) program in 2022, to focus on whether APAs continue to provide the right service for taxpayers. As part of the review, the tax authorities will consider how to tailor the APA process to better align to risk and taxpayer behavioural indicators. The review is expected to commence in early 2022 and will include a public consultation process.
Cyprus:
On 24 January 2022, the Cyprus tax authorities issued a set of 14 “
Frequently Asked Questions
” regarding the tax treatment of intragroup back-to-back financing transactions, as set out in an Interpretive Circular dated 30 June 2017. The answers to the FAQs are applicable to all transactions that fall within the scope of the back-to-back circular and relate to loan agreements concluded as of the date of issue of the FAQs, as well as to those loan agreements that were concluded prior to that date that have not been examined by the Tax Department.
Malta
: Malta’s Commissioner for Revenue sought feedback regarding
draft transfer pricing rules
that would implement legislation prescribing the application of the arm’s length principle to the pricing of transactions between associated enterprises that fall within the scope of the rules. The draft rules also include an APA program. The Commissioner invited interested parties to provide general tax policy comments in the area of transfer pricing, as well as specific views on the draft rules and possible alternative approaches. The consultation period ran through 28 February 2022, and the final transfer pricing rules are expected to be published during the last quarter of 2022.
OECD
: The OECD on 28 February 2022 released the third batch of 2021/2022 updates to the
transfer pricing country profiles
of 28 jurisdictions, including Brazil, Canada, China, the UK and the U.S.. This release also includes new chapters for six countries -- Honduras, Iceland, Jamaica, Papua New Guinea, Senegal and Ukraine -- bringing the total number of countries covered to 91. The updated country profiles add new information on countries’ legislations and practices regarding the transfer pricing aspects of financial transactions and the application of the Authorised OECD Approach (AOA) on the attribution of profits to permanent establishments.
South Africa
: The South Africa Revenue Service (SARS) on 11 February 2022 issued a
draft interpretation note
on intragroup loans for public comment, which must be submitted by 29 April 2022. SARS had previously issued similar draft notes in 2013 and 2017, but those drafts were never finalized. The new draft reflects changes in transfer pricing legislation and includes additional detail and new sections. The draft also takes into account the OECD’s Transfer Pricing Guidance on Financial Transactions released in 2020.
Back to overview
Please ensure Javascript is enabled for purposes of
website accessibility