Worldwide transfer pricing reference guide 2014

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Laos Taxing authority and tax law Tax authority: Tax Department Tax law: Amended Tax Law No 21/NA dated 20 December 2011 Relevant regulations and rulings There are no transfer pricing regulations in Laos. Laos has concluded Double Tax Treaties (DTT) with Brunei, China, Korea, Malaysia, Myanmar, Thailand and Vietnam, which are currently effective. Priorities/pricing methods By regulations, there are no specified pricing methods in Laos. In practice, the Tax Department may adopt a different pricing method such as averaged or market prices. Frequency of tax audit and transfer pricing scrutiny by the tax authority The Lao Tax Department conducts annual tax audit/assessment after the corporate taxpayers submit their annual corporate income tax returns and financial statements in March of the following year. There is no specific transfer pricing audit in Laos. Worldwide transfer pricing reference guide 174
Latvia Taxing authority and tax law Tax authority: The State Revenue Service Tax law: The arm’s length principle is established in the Law on Corporate Income Tax. Article 12 of the Law on Corporate Income Tax determines that the taxable income of the taxpayer may be adjusted upwards if related party transactions are not at arm’s length. Transfer pricing documentation requirements are laid down in the Law on Taxes and Duties. Relevant regulations and rulings Cabinet Regulations No. 556, promulgated on 4 July 2006, set the transfer pricing methods applicable for determining arm’s length prices applied in related party transactions. Additionally, specific Cabinet Regulations set requirements regarding the conclusion of APAs. OECD Guidelines treatment Latvian transfer pricing legislative acts contain a reference to the OECD Guidelines on the application of the transfer pricing methods. The State Revenue Service in most cases accepts the principles stipulated in the OECD Guidelines regarding structure of transfer pricing documentation. Priorities/pricing methods Five methods are accepted: CUP, Resale Price, Cost Plus, Profit Split and TNMM Transfer pricing penalties There is no specific penalty for not having transfer pricing documentation. In case the prices applied in transactions between related parties are not at arm’s length, the taxable income of the taxpayer may be adjusted upwards and a penalty of 20% to 30% on the amount along with a late payment penalty (annual rate of 18%) on the additionally payable corporate income tax may be applied. Penalty relief There is no specific penalty relief with respect to transfer pricing adjustments. As per ordinary procedure, penalty imposed in the result of a tax audit may be reduced by 50%. In addition to this, in practice the existence of proper transfer pricing documentation reduces risk of transfer pricing adjustments. Documentation requirements Taxable persons with annual net turnover exceeding EUR1.43 million are obliged to prepare transfer pricing documentation for all related party transactions with annual value over EUR14, 300. According to the Law on Taxes and Duties, transfer pricing documentation should contain the following information: • General overview of the industry — brief description of taxpayer’s operations in recent years • Organizational and legal structure of the taxpayer and related entity, including description of internal relations • Information on taxpayer’s business strategy — market strategy, product distribution strategy and supply chain as well as sales and management strategy that may potentially affect pricing policy of intercompany transactions • Description of intangibles that may affect the transfer price (if any) • Information identifying operations between related companies — functions of the group members, including associated risks and assets employed, as well as role and responsibility of each group member involved in the transactions and information regarding restructuring of taxpayer’s operations resulting in transfer (acquisition) of business functions, assets or risks to (from) related party for the price compliant to the market price • Description of the goods or services in the transaction between the taxpayer and related party • Terms and conditions of the agreement concluded between the taxpayer and related party • Forecast for taxpayer’s operating activities in relation to the agreement concluded with related entity Worldwide transfer pricing reference guide 175
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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
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Gabon (continued) Transfer pricing-
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Georgia (continued) Documentation r
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Germany Taxing authority and tax la
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Germany (continued) For late filing
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Ghana Taxing authority and tax law
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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 and 164: Japan (continued) APA opportunity U
Page 165 and 166: Kazakhstan Taxing authority and tax
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: Kuwait (continued) Documentation re
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
Page 213 and 214: New Zealand (continued) Frequency o
Page 215 and 216: Nigeria Taxing authority and tax la
Page 217 and 218: Norway Taxing authority and tax law
Page 219 and 220: Norway (continued) Frequency of tax
Page 221 and 222: Oman (continued) Frequency of tax a
Page 223 and 224: 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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