Transfer Pricing Alert

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Transfer Pricing Alert December 2016 Issue has been released. 

EY - TP Alert December 2016 Download
(English pdf, 2.8mb)


  • Hong Kong Hong Kong publishes consultation paper on measures to counter BEPS

    On 26 October 2016, The Government of Hong Kong (the Government) announced a consultation paper on measures to counter base erosion and profit shifting (BEPS) (the Consultation Paper), published on the Financial Services and the Treasury Bureau’s website.
    The Consultation Paper proposes the introduction of transfer pricing rules in Hong Kong, including adoption of the three-tiered approach to transfer pricing documentation recommended by the Organisation for Economic Co-operation and Development (OECD). Additionally, key action areas include a multilateral instrument, spontaneous exchange of information of tax rulings, and dispute resolution.
    The Consultation Paper consists of seven chapters, namely:

    • Chapter 1: Overview of the BEPS package
    • Chapter 2: Implementation strategy of Hong Kong
    • Chapter 3: Transfer pricing regulatory regime
    • Chapter 4: Transfer pricing documentation and CbC reporting
    • Chapter 5: Multilateral Instrument
    • Chapter 6: Other related matters
    • Chapter 7: Views sought

    The closing date of the consultation period is 31 December 2016. Relevant amendment bill(s) are planned to be introduced into the Legislative Council in mid-2017.


  • Netherlands Dutch Government publishes Decree extending deadline for filing first notifications under Country-by-Country reporting rules 

    On 21 November 2016, the Dutch Secretary of Finance published a Decree by which the date for Dutch constituent entities to comply with the first notification requirement under the Dutch Country-by-Country (CbC) reporting rules has been extended.
    Based on the Dutch Corporate Income Tax Act (CITA), Dutch constituent entities of a multinational enterprise (MNE) group must notify the Dutch tax authorities about the identity and tax residence of the entity filing the CbC report by the last day of their reporting fiscal year. By means of the Decree, the deadline for filing the notification for the first CbC report has been extended to 1 September 2017. If the reporting fiscal year ends after 31 August 2017, the general notification rule will apply and the notification should be submitted by the last day of the reporting fiscal year.
    Additionally, the Decree states that:

    • A software tool has been developed to submit these notifications and that it is intended to make the use of this software tool mandatory
    • It is intended to officially confirm that the Dutch tax authorities will accept CbC reports that have been filed in other jurisdictions on a voluntary basis (parent surrogate filing) in line with guidance issued by the Organisation for Economic Co-operation and Development (OECD)



 TP Alert 2016 Issues
November 2016 (pdf, 1.4mb)
  • Singapore Singapore releases tax guide on Country-by-Country reporting
  • China China’s SAT issues new guidance on administration of advance pricing agreements
October 2016 (pdf, 1.4mb)
  • Republic of Korea Korea’s Amendment to Law for Coordination of International Tax Affairs (“LCITA”): Documentation Requirements for Taxpayers with Overseas Related Party Transaction
  • Russia Russia issues new version of draft law on BEPS Action 13 implementation
August 2016 (pdf, 1.9mb)
  • Republic of Korea Korea implements country-by-country report submission requirements through amendments to the LCITA
  • Russia Russia issues draft law on country-by-country reporting requirements for public consultation
July 2016 (pdf, 711kb)
  • Korea Korean Government Signed Multilateral Competent Authority Agreement on exchange of Country-by-Country Reports
  • United Kingdom UK issues consultation on transfer pricing secondary adjustments
  • Belgium Belgium to implement formal transfer pricing documentation and country-by country reporting requirements
June 2016 (pdf, 973kb)
  • Korea Korea’s Tax Tribunal rules on transfer pricing issues regarding working capital adjustments
  • Japan The NTA releases guidance on transfer pricing documentation requirements
  • Australia New transfer pricing guidance impacts profic attribution in global value chains starting 1 July 2016
May 2016 (pdf, 1.90mb)
  • Korea On 14 April 2016, the Ministry of Strategy and Finance (“MOSF”) announced ‘No. 2016-007’ providing specifics on applicable entities and submitter of the two reports constituting the International Related Party Transaction Integrated Report (the Master File and the Local File).
  • United States The US Internal Revenue Service (IRS) Advance Pricing and Mutual Agreement (APMA) program issued the 17th annual Advance Pricing Agreement (APA) report (the Report) on 31 March 2016 in Announcement 2016-12.
  • India Any company considering filing a request for a unilateral advance pricing arrangement (APA) with India should be aware that India has decided that the high level details of all concluded unilateral APAs will be shared with the competent authorities of all such countries where the Indian applicant’s related parties are located, including immediate, intermediate and ultimate parent companies.
April 2016 (pdf, 1.19mb)
  • Malaysia Malaysia plans to introduce Country-by-Country Reporting and Master File-Local File documentation requirements.
  • Canada Canada issues Federal budget 2016-2017 including BEPS Action 13 initiatives.
  • Turkey Turkish Revenue Administration implements new transfer pricing documentation approach including CbC reporting.
March 2016 (pdf, 1.09mb)
  • Korea 2015 Amendments to the Ministerial Regulation of the LCITA: Specific regulations regarding the submission of “International Related Party Transaction Integrated Report” by multinational enterprises.
  • Japan Japan is expected to adopt many of the BEPS recommendations.
January 2016 (pdf, 3.11mb)
  • Korea 2015 Essential guide to contemporaneous transfer pricing (“TP”) documentation in Korea.
  • Singapore Detailed discussion
  • Vietnam Key features of Circular 201
  • Indonesia Parties authorized to apply for APA in Indonesia, APA process according to PMK-07 etc.


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