AUSTRALIA
Australian Taxation Office: PS LA 2015/3 Approval process for the application of subsections 815-130(2) to 815-130(4) of the Income Tax Assessment Act 1997 (ITAA 1997)
Australian Taxation Office: PS LA 2014/3 Simplifying transfer pricing record keeping
Australian Taxation Office: PS LA 2014/2 Administration of transfer pricing penalties for income years commencing on or after 29 June 2013
Australian Taxation Office: TR 2014/D4 Income Tax: Transfer Pricing: Documentation Requirements
Australian Taxation Office: TR 2014/8 Income tax: transfer pricing documentation and Subdivision 284-E
Australian Taxation Office: TR 2014/6 Income tax: transfer pricing – the application of section 815-130 of the Income Tax Assessment Act 1997
Australian Taxation Office: PS LA 3673 (draft) Guidance for transfer pricing documentation
Australian Taxation Office: PS LA 2015/4 Advance Pricing Arrangements
Australian Taxation Office: PS LA 2011/1 ATO’s Advance Pricing Arrangement Program
Australian Taxation Office: TR 2000/16 International transfer pricing transfer pricing and profit reallocation adjustments, relief from double taxation and the Mutual Agreement Procedure
Australian Taxation Office: TR 98/11 Documentation and practical issues associated with setting and reviewing transfer pricing in international dealings
Australian Taxation Office: TR 97/20 Arm’s length transfer pricing methodologies for international dealings
Australian Taxation Office: TR 94/14 application of Division 13 of Part III (international profit shifting) – some basic concepts underlying the operation of Division 13 and some circumstances in which section 136AD will be applied
Australian Taxation Office: Tax Treaties
Australian Taxation Office: Tax Information Exchange Agreements
Australian Taxation Office: International dealings schedule 2012 (NAT 73345-6.2012)
Australian Taxation Office: International dealings schedule instructions 2012
Australian Taxation Office: Transfer pricing
Australian Taxation Office: International transfer pricing – Introduction to concepts and risk assessment
Australian Taxation Office: International transfer pricing – a simplified approach to documentation and risk assessment for small to medium businesses
Australian Taxation Office: How we check compliance
OECD: Transfer Pricing in Australia
Australian Taxation Office: Practice Statement (PS2009/21): Applying for a Valuation Advice relating to Transfer Pricing (13 July 2009)
Australian Taxation Office: Advance pricing arrangement program updates
- Advance Pricing Arrangement Program Update 2010-11
- Advance Pricing Arrangement Program Update 2009-10
- Advance Pricing Arrangement Program Update 2008-09
- Advance Pricing Arrangement Program Update 2007-08
- Advance Pricing Arrangement Program Update 2006-07
- Advance Pricing Arrangement Program Update 2005-06
BANGLADESH
National Board Of Revenue: Income Tax Ordinance, 1984 (as amended, July 2014)
National Board Of Revenue: The Income Tax Ordinance, 1984 (XXXVI of 1984), Chapter XIA – Transfer Pricing (July 2014)
National Board Of Revenue: Income Tax Ordinance, 1984 (Ord. XXXVI of 1984), Rule 75A Statement Of International Transactions (see pp. 9-13)
CHINA
State Administration of Taxation
General Administration of Customs
The People’s Republic of China Website
OECD: Transfer Pricing in China
State Administration of Taxation: China advanced pricing arrangement annual Reports
- China Advanced Pricing Arrangement Annual Report 2013
- China Advanced Pricing Arrangement Annual Report 2012
- China Advanced Pricing Arrangement Annual Report 2011
- China Advanced Pricing Arrangement Annual Report 2010
HONG KONG
Inland Revenue Department (Hong Kong): Hong Kong Competent Authority
Inland Revenue Department (Hong Kong): Double Taxation Relief and Exchange of Information Arrangements
Comprehensive Double Taxation Agreements
Limited Double Taxation Agreements
Tax Information Exchange Agreements
Inland Revenue Department (Hong Kong): Advance Pricing Arrangement
Inland Revenue Department (Hong Kong): Public Forms and Pamphlets
Inland Revenue Department (Hong Kong): Departmental Interpretation and Practice Notes
DIPN No. 46 Transfer Pricing Guidelines – Methodologies and Related Issues (December 2009)
DIPN No. 47 (Revised) Exchange of Informations (January 2014)
DIPN No. 48 Advance Pricing Arrangement (March 2012)
Inland Revenue Department (Hong Kong): Hong Kong Guide to Taxes
INDIA
OECD: Transfer pricing in India
Income Tax Department: International Taxation
Income Tax Department: Double Taxation Avoidance Agreements
Income Tax Department: Tax Treaties Comparisons
Income Tax Department: Tax Information Exchange Agreements
Income Tax Department: Relevant provisions for non-resident
Income Tax Department: Withholding Tax
Income Tax Department: Notification No. 36 of 2012 on the APA Program
JAPAN
OECD: Transfer pricing in Japan
National Tax Agency of Japan: Commissioner’s Directive on the Operation of Transfer Pricing (Administrative guidelines)
National Tax Agency of Japan: Supplement. Reference Case Studies on Application of Transfer Pricing Taxation
National Tax Agency of Japan: Commissioner’s Directive on the Mutual Agreement Procedure (Administrative guidelines)
Ministry of Finance Japan: Tax Conventions
National Tax Agency of Japan: Mutual agreement procedure (MAP) and advance pricing arrangement (APA) reports
- Mutual Agreement Procedure Report 2013
- Mutual Agreement Procedure Report 2012
- Mutual Agreement Procedure Report 2011
- Advance Pricing Arrangement Program Report 2010
- Advance Pricing Arrangement Program Report 2009
- Advance Pricing Arrangement Program Report 2008
- Advance Pricing Arrangement Program Report 2007
- Advance Pricing Arrangement Program Report 2006
- Advance Pricing Arrangement Program Report 2005
- Advance Pricing Arrangement Program Report 2004
MALAYSIA
Inland Revenue Board of Malaysia
OECD: Transfer pricing in Malaysia
Inland Revenue Board of Malaysia: Transfer pricing information on cross border transaction
Inland Revenue Board of Malaysia: LHDN.01/46/197-1 LHDN Malaysia Transfer Pricing Guidelines 2012
Inland Revenue Board of Malaysia: Form MNE [Pin 2/2012] Information on Cross Border Transaction
Inland Revenue Board of Malaysia: LHDN.01/46/198-1 LHDN Malaysia Advance Pricing_Arrangement Guidelines 2012
NEW ZEALAND
Inland Revenue (New Zealand): International Taxation
Inland Revenue (New Zealand):Transfer pricing
OECD: Transfer pricing in New Zealand
Inland Revenue (New Zealand): Transfer pricing practice issues
Inland Revenue (New Zealand): Transfer Pricing Guidelines. A guide to the application of section GD 13 of New Zealand’s Income Tax Act 1994
Inland Revenue (New Zealand): Taxation of multinationals and BEPS (15 August 2013)
Inland Revenue (New Zealand): Timeline for BEPS-related tax policy work (14 November 2014)
Inland Revenue (New Zealand): Advance pricing agreements (APAs)
Inland Revenue (New Zealand): Transfer pricing questionnaires
Foreign-owned multinationals
New Zealand-owned multinationals
New Zealand branches
PAKISTAN
Securities and Exchange Commission of Pakistan (SECP)
Federal Board of Revenue: Double Taxation Treaties
Federal Board of Revenue: Withholding Tax Regime(Rates Card)
Federal Board of Revenue: Training on International Taxation and Tax Avoidance
Notification No. S.R.O. 66 (I)/2003
Report of the Task Force on Transfer Pricing (December 30, 2005)
National Law Provisions Concerning International Taxation
Transfer Pricing – Concepts and Issues
SINGAPORE
Inland Revenue Authority of Singapore: Transfer pricing
OECD: Transfer pricing in Singapore
Inland Revenue Authority of Singapore: IRAS Circular Transfer Pricing Guidelines (2nd Edition, January 6, 2015)
Inland Revenue Authority of Singapore: IRAS Circular Transfer Pricing Guidelines (February 23, 2006)
Inland Revenue Authority of Singapore: IRAS Consultation on transfer pricing documentation (September 2014)
Inland Revenue Authority of Singapore: IRAS Supplementary e-Tax Guide – Transfer Pricing Guidelines for Related Party Loans and Related Party Services (February 23, 2009)
Inland Revenue Authority of Singapore: IRAS Circular Advance Ruling System (June 8, 2005; April 2, 2012)
Inland Revenue Authority of Singapore: IRAS Supplementary Circular – Supplementary Admininistrative Guidance on Advance Pricing Arrangements (October 20, 2008)
TAIWAN (REPUBLIC OF CHINA)
Taxation Administration, Ministry of Finance, R.O.C.: Transfer Pricing System in the Republic of China
Ministry of Finance, R.O.C.: Guide to ROC Taxes 2013
Ministry of Finance, R.O.C.: Taiwan (Republic of China) Guide to ROC Taxes (2013) Chapter 6 International Tax
THAILAND
The Revenue Department of Thailand: Transfer pricing
The Revenue Department of Thailand: Guidelines on the Determination of Market Price
The Revenue Department of Thailand: Multinational Enterprises and Transfer Pricing (June 2002)
The Revenue Department of Thailand: Guidance on APA Process
VIETNAM
The Ministry of Finance: Circular No. 66/2010/TT-BTC Guiding the Determination of Market Prices in Business Transactions Between Associated Parties (April 22, 2010)
The Ministry of Finance: Circular No. 117/2005/TT-BTC Guiding the Determination of Market Prices in Business Transactions Between Associated Parties (December 19, 2005)
The Ministry of Finance: Appendix 1 – Circular No. 117/2005/TT-BTC Guiding the Determination of Market Prices in Business Transactions Between Associated Parties (December 19, 2005)
OTHER COUNTRIES
OECD: Transfer pricing in Korea
Indonesia Directorate General of Taxes: Recent Development in Indonesian Transfer Pricing
Department of Finance (Philippines): Revenue Regulations No. 2-2013 Transfer Pricing Guidelines (January 2013)
Fiji Revenue & Customs Authority: Fiji Revenue & Customs Authority Transfer Pricing Guidelines (January 2012)