ASIA AND OCEANIA

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


BANGLADESH

National Board Of Revenue

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

Tax Treaties

The People’s Republic of China Website

Doing business in China

OECD: Transfer Pricing in China

State Administration of Taxation: China advanced pricing arrangement annual Reports


HONG KONG

Inland Revenue Department (Hong Kong): Hong Kong Competent Authority

Inland Revenue Department (Hong Kong): Double Taxation Relief and Exchange of Information Arrangements

Mutual Agreement Procedure

Comprehensive Double Taxation Agreements

Limited Double Taxation Agreements

Exchange of Information

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. 29 Tax Relations Between The Hong Kong Special Administration Region and the People’s Republic of China (August 1997)

DIPN No. 32 (Revised) Arrangement Between the Mainland of China and the Hong Kong Special Administration Region for the Avoidance of Double Taxation on Income (October 2011)

DIPN No. 44 (Revised) Arrangement Between the Mainland of China and the Hong Kong Special Administration Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (August 2008)

DIPN No. 45 Relief from Double Taxation due to Transfer Pricing or Profit Reallocation Adjustments (April 2009)

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

Income Tax Department

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


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

Federal Board of Revenue

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)