Worldwide transfer pricing reference guide 2014

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Jordan Taxing authority and tax law Taxing authority: Income and Sales Tax Department. Tax law: Currently, there are no local transfer pricing regulations in Jordan, but around 28 tax treaties have been concluded which contain an article which resembles Article 9 OECD Model Tax Convention on “Associated Enterprises.” Worldwide transfer pricing reference guide 164
Kazakhstan Taxing authority and tax law In Kazakhstan, the tax and customs authorities are authorized to regulate transfer pricing. The tax authorities include: • The Tax Committee of the Ministry of Finance (TCMF) of the Republic of Kazakhstan and its territorial tax bodies • The customs authorities, including the Customs Control Committee (CCC) of the Ministry of Finance, its territorial subdivisions, custom houses, customs points, checkpoints at the customs border of the Republic of Kazakhstan, and specialized customs offices Relevant regulations and rulings The Law of the Republic of Kazakhstan, No. 67–IV on Transfer Pricing of 5 July 2008, regulates transfer pricing. Additionally, transfer pricing in Kazakhstan is regulated by the following subordinate legal acts: • Rules for monitoring transactions (No. 1324 of 11 November 2011) • Rules for concluding agreements on the application of transfer pricing (No. 1197 of 24 October 2011) • Rules on the procedure for cooperation with authorized bodies in examining transfer pricing issues (No. 129 of 26 March 2009) • List of goods (including work and services) in international business transactions which are subject to transaction monitoring (No. 293 of 12 March 2009) • List of officially recognized sources of information on market prices (No. 292 of 12 March 2009) • List of exchange quoted goods (No.638 of 6 May 2009) OECD Guidelines treatment Although Kazakhstan is not a member of the OECD, the current transfer pricing law in Kazakhstan has some common features with the OECD Guidelines. However one of the principal differences from the OECD Guidelines is that the Kazakhstan transfer pricing legislation targets all international business transactions, regardless of whether the parties are related or not. Priorities/pricing methods The transfer pricing law supports five pricing methods, given in order of priority: CUP, Cost Plus, Resale Price, Profit Split and TNMM. Although the methods have similar names, their application may differ from that described in the OECD Guidelines. Transfer pricing penalties Special penalties are in place for failure to comply with the documentation requirements established by the transfer pricing legislation (i.e., monitoring reporting and documentation supporting the transaction price). The maximum amount of penalty is set at approximately US$4,000. Transfer pricing penalties are also imposed on individuals for personal liability for an administrative violation. It also includes criminal liability, if the tax amount misreported exceeds approximately US$226,000. Such violations can result in investigation by the financial police and in the prosecution of individuals who are held responsible for violations. The penalty for an understatement of tax resulting from a transfer pricing adjustment is up to 50% of the additional accrued tax amount. In addition, interest for the delayed payment of the additionally assessed tax resulting from the transfer pricing adjustment is calculated at two and a half times the National Bank refinancing rate. Penalty relief The legislation in Kazakhstan considers cases for penalty relief when an entity may be exempt from administrative liability. These cases, amongst others, include exemption from administrative liability in connection with active repentance, an insignificant violation, expiration of the statute of limitations, and exemption on the basis of an act of amnesty. Despite legal provisions allowing for exemption, in practice, implementation is quite rare. Worldwide transfer pricing reference guide 165
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Worldwide Transfer Pricing Referenc
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Worldwide transfer pricing referenc
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Nigeria 215 Norway 217 Oman 220 Pak
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The content is current as of 28 Feb
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CUP (comparable uncontrolled price)
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Albania (continued) Priorities/pric
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Algeria Taxing authority and tax la
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Algeria (continued) Return disclosu
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Angola (continued) Transfer pricing
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Argentina Taxing authority and tax
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Argentina (continued) Transfer pric
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Australia Taxing authority and tax
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Australia (continued) Priorities/pr
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Australia (continued) Documentation
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Australia (continued) Frequency of
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Austria (continued) Documentation r
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Bahrain Taxing authority and tax la
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Bangladesh (continued) Penalty reli
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Belgium Taxing authority and tax la
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Belgium (continued) Statute of limi
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Bolivia Taxing authority and tax la
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Botswana Taxing authority and tax l
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Brazil (continued) Relevant regulat
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Brazil (continued) Priorities/prici
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Brunei Taxing authority and tax law
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Bulgaria (continued) Transfer prici
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Bulgaria (continued) Return disclos
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Cameroon Taxing authority and tax l
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Canada Taxing authority and tax law
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Canada (continued) Documentation re
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Chile Taxing authority and tax law
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Chile (continued) Return disclosure
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China (continued) Documentation req
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Colombia Taxing authority and tax l
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Colombia (continued) Penalty relief
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Republic of Congo Taxing authority
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Costa Rica Taxing authority and tax
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Croatia Taxing authority and tax la
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Croatia (continued) Frequency of ta
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Czech Republic Taxing authority and
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Denmark Taxing authority and tax la
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Denmark (continued) Documentation d
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Dominican Republic Taxing authority
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Dominican Republic (continued) Expe
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Ecuador (continued) Priorities/pric
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Ecuador (continued) Return disclosu
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Egypt Taxing authority and tax law
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Egypt (continued) Frequency of tax
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El Salvador (continued) Transfer pr
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Estonia Taxing authority and tax la
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Fiji Taxing authority and tax law T
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Fiji (continued) Frequency of tax a
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Finland (continued) Documentation r
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France (continued) Transfer pricing
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France (continued) Documentation re
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France (continued) Expected reactio
Page 113 and 114: Gabon (continued) Transfer pricing-
Page 115 and 116: Georgia (continued) Documentation r
Page 117 and 118: Germany Taxing authority and tax la
Page 119 and 120: Germany (continued) For late filing
Page 121 and 122: Ghana Taxing authority and tax law
Page 123 and 124: Ghana (continued) APA opportunity T
Page 125 and 126: Greece (continued) Transfer pricing
Page 127 and 128: Guatemala Taxing authority and tax
Page 129 and 130: Honduras Taxing authority and tax l
Page 131 and 132: Hong Kong (SAR) Taxing authority an
Page 133 and 134: Hong Kong (SAR) (continued) APA opp
Page 135 and 136: Hungary (continued) Priorities/pric
Page 137 and 138: Hungary (continued) Documentation r
Page 139 and 140: Iceland Taxing authority and tax la
Page 141 and 142: India Taxing authority and tax law
Page 143 and 144: India (continued) Documentation req
Page 145 and 146: Indonesia Taxing authority and tax
Page 147 and 148: Indonesia (continued) Frequency of
Page 149 and 150: Ireland Taxing authority and tax la
Page 151 and 152: Ireland (continued) Frequency of ta
Page 153 and 154: Israel (continued) Priorities/prici
Page 155 and 156: Italy Taxing authority and tax law
Page 157 and 158: Italy (continued) Transfer pricing
Page 159 and 160: Italy (continued) Frequency of tax
Page 161 and 162: Japan (continued) Transfer pricing
Page 163: Japan (continued) APA opportunity U
Page 167 and 168: Kazakhstan (continued) Frequency of
Page 169 and 170: Kenya (continued) Documentation req
Page 171 and 172: Kosovo (continued) Documentation re
Page 173 and 174: Kuwait (continued) Documentation re
Page 175 and 176: Latvia Taxing authority and tax law
Page 177 and 178: Lebanon Taxing authority and tax la
Page 179 and 180: Lithuania Taxing authority and tax
Page 181 and 182: Luxembourg Taxing authority and tax
Page 183 and 184: Former Yugoslav Republic of Macedon
Page 185 and 186: Malaysia Taxing authority and tax l
Page 187 and 188: Malaysia (continued) Frequency of t
Page 189 and 190: Maldives (continued) Statute of lim
Page 191 and 192: Malta (continued) Return disclosure
Page 193 and 194: Mauritius (continued) APA opportuni
Page 195 and 196: Mexico (continued) Transfer pricing
Page 197 and 198: Mexico (continued) Return disclosur
Page 199 and 200: Montenegro (continued) Frequency of
Page 201 and 202: Morocco (continued) Transfer pricin
Page 203 and 204: Myanmar Taxing authority and tax la
Page 205 and 206: Namibia Taxing authority and tax la
Page 207 and 208: Netherlands Taxing authority and ta
Page 209 and 210: Netherlands (continued) Statute of
Page 211 and 212: New Zealand Taxing authority and ta
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Nigeria Taxing authority and tax la
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Norway Taxing authority and tax law
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Norway (continued) Frequency of tax
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Oman (continued) Frequency of tax a
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Panama Taxing authority and tax law
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Panama (continued) Expected reactio
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Papua New Guinea (continued) Docume
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Peru Taxing authority and tax law T
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Peru (continued) Frequency of tax a
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Philippines (continued) Transfer pr
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Poland Taxing authority and tax law
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Poland (continued) Transfer pricing
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Poland (continued) Return disclosur
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Poland (continued) APA opportunity
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Portugal (continued) Transfer prici
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Portugal (continued) APA opportunit
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Qatar (continued) OECD guidelines t
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Qatar (continued) Return disclosure
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Romania (continued) Documentation r
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Russian Federation Taxing authority
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Russian Federation (continued) Freq
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Saudi Arabia (continued) Transfer p
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Senegal (continued) Documentation r
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Serbia Taxing authority and tax law
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Singapore Taxing authority and tax
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Singapore (continued) Frequency of
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Slovak Republic (continued) Documen
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Slovenia Taxing authority and tax l
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Slovenia (continued) Transfer prici
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South Africa (continued) Penalty re
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South Korea (Republic of Korea) Tax
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South Korea (Republic of Korea) (co
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Spain (continued) Penalty relief So
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Spain (continued) APA opportunity T
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Sri Lanka (continued) Return disclo
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Sweden (continued) Documentation re
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Switzerland Taxing authority and ta
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Taiwan Taxing authority and tax law
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Taiwan (continued) Return disclosur
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Tanzania Taxing authority and tax l
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Thailand Taxing authority and tax l
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Thailand (continued) Frequency of t
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Turkey (continued) Priorities/prici
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Uganda Taxing authority and tax law
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Ukraine Taxing authority and tax la
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Ukraine (continued) Transfer pricin
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United Kingdom Taxing authority and
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United Kingdom (continued) Transfer
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United States (continued) Transfer
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Uruguay Taxing authority and tax la
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Uruguay (continued) APA opportunity
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Venezuela Taxing authority and tax
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Venezuela (continued) Expected reac
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Vietnam (continued) Relevant regula
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Vietnam (continued) Documentation d
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Zimbabwe Taxing authority and tax l
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Zimbabwe (continued) Relevant regul
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Transfer pricing contacts Area cont
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Jurisdiction contacts • El Salvad
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Jurisdiction contacts • Rep. of C
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Worldwide transfer pricing reference guide 2014

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