Transfer Pricing (TP) Market Insights (11)

Global Transfer Pricing Updates
In this edition, we have covered the Transfer Pricing updates of Africa, Singapore, Australia, Kenya, Nigeria, Malta and Qatar for the month of May 2021. 1. Africa – 3rd edition released on Tax Transparency and Exchange of Tax Information Given the high levels of illicit financial flows from African countries and recognising the potential o...
Jorge Castro Quoted on Growing Bipartisan Recognition for IRS to Address Tax Gap in Bloomberg Law
Tax Member Jorge Castro, former Democratic Congressional tax aide and Counselor to the IRS Commissioner during the Obama Administration, said there is "growing bipartisan recognition for the IRS to address the tax gap, which has been grown significantly." His comments were in response to legislation released yesterday by the House Appropriations Co...
Singapore: Future proof now, not later, as transfer pricing scrutiny evolves
Look at any of the largest tax audit and litigation cases of the last few years and it is more likely than not that some form of transfer pricing (TP) sits at - or very near - the heart of each one. It is therefore of little surprise that transfer pricing has again been confirmed as the leading source of risk to tax departments globally, according ...
The changing landscape of transfer pricing in the United States: Section 482 audits
The landscape of transfer pricing in the United States is subject to continuing change. The IRS is close to promulgating permanent aggregation regulations to replace temporary regulations due to expire. These anticipated new regulations may make it easier for the IRS to disregard complex transfer pricing structures and, further, reflect the US taxi...
Jordan introduces formal transfer pricing requirements
In briefOn June 7, 2021, the Hashemite Kingdom of Jordan (“Jordan”) published the Regulation No. 40 for the year 2021 in its Official Gazette (“the regulation”). The regulation introduces formal transfer pricing (“TP”) requirements in accordance with the provisions of the Article 77/A of the Income Tax Law No. 34 of 2014 (“the Income Tax Law”) and ...
Transfer pricing: The year that was and what’s next
The transfer pricing compliance requirements introduced by the Bureau of Internal Revenue (BIR) in July 2020 are believed to be game-changers for taxpayers to ensure that their transactions with their related parties are planned, executed, and carried out in the same manner as dealing with independent third parties — what is called the “arm’s-lengt...
International Tax Advisory: IRS APMA’s Results May Suggest COVID-19 Immunity
On March 23, 2021, the IRS issued its Announcement and Report Concerning Advance Pricing Agreements (2020 APA Report), which presents the key results of the IRS’s Advance Pricing and Mutual Agreement Program (APMA). The 2020 APA Report provides general information about the operation of the program, including staffing, and statistical information a...
TP deadlines likely to be extended by 3 months
Deadlines for compliance with the transfer pricing obligations are likely to be extended again.On 25 February 2021, the Transfer Pricing and Valuation Department informed that the Public Finance Commission of the Sejm adopted an adjustment to the bill of amendment of the excise duty act and some other acts (form 860). The deadlines for submission o...
Noteworthy rule changes impacting transfer pricing documentation requirements for fiscal year 2020 and beyond
2020 has been an unprecedented year filled with many uncertainties. In the transfer pricing world, the OECD has been busy addressing transfer pricing implications of the coronavirus disease 2019 (COVID-19) and Digital Services Taxation, and countries continued to implement changes to their respective transfer pricing documentations rules. This mo...
Effective Management of Transfer Pricing: Introduction to new Transfer Pricing Provisions in Malaysia
Failure to Furnish Contemporaneous Transfer Pricing DocumentationEffective 1 January 2021, a new Section 113B was introduced into the Malaysian Income Tax Act (“the Act”), setting out the penalty for failure to furnish contemporaneous transfer pricing documentation. On conviction: Fine of MYR 20,000 – MYR 100,000 or imprisonment of up to 6 months. ...