Worldwide transfer pricing reference guide 2014

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Mauritius Taxing authority and tax law Mauritius Revenue Authority (MRA) and Income Tax Act 1995 (ITA 1995). Relevant regulations and rulings There are no relevant transfer pricing regulations. Under Section 159 of the ITA 1995, any person may apply for an advanced ruling. The MRA should issue the ruling within 30 days of the receipt of the application. OECD guidelines treatment Since Mauritius does not have any specific transfer pricing laws, this question never arose. Based on experience with the MRA, the OECD Guidelines have been used to determine the arm’s length price. Priorities/pricing methods Not applicable. Transfer pricing penalties The penalty for any late payment of tax is 5% and monthly interest at the rate of 1% applies. Penalty relief Even though Mauritius does not have any transfer pricing regulations, the MRA can challenge intercompany transactions. The Director- General of the MRA is empowered to waive any interests and penalties where it is satisfied that the error is attributable to a just or reasonable cause. Documentation requirements As Mauritius does not have any transfer pricing laws, there is nothing specific that is prescribed or requested by the MRA through its statement of practice. It is recommended that all supporting documents such as comparable data and basis of allocation of profits are maintained. Documentation deadlines The MRA has up to five years from the submission of the tax return to issue a notice of assessment. The time frame to keep any documents under the Mauritian corporate laws is seven years. Statute of limitations on transfer pricing assessments Whilst there is no transfer pricing laws in Mauritius, the MRA may challenge intercompany transactions and has up to five years from the submission of the tax return to issue a notice of assessment. In the case of fraud and wilful neglect, the time limit of five years does not apply. Return disclosures/related party disclosures The tax payer should intimate in the return whether related party transactions have been made at arm’s length or not. Transfer pricing–specific returns Not applicable. Frequency of tax audit and transfer pricing scrutiny by the tax authority The likelihood of an annual tax audit is medium. The likelihood that transfer pricing will be reviewed as part of that audit is also medium. The likelihood that the transfer pricing methodology will be challenged is high. Worldwide transfer pricing reference guide 192
Mauritius (continued) APA opportunity Under the Mauritian tax laws, an advanced ruling is possible. Expected reaction to OECD Report on BEPS Not applicable. Worldwide transfer pricing reference guide 193
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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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Ghana (continued) APA opportunity T
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Greece (continued) Transfer pricing
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Guatemala Taxing authority and tax
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Honduras Taxing authority and tax l
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Hong Kong (SAR) Taxing authority an
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Hong Kong (SAR) (continued) APA opp
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Hungary (continued) Priorities/pric
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Hungary (continued) Documentation r
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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 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: Malta (continued) Return disclosure
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
Page 225 and 226: Panama (continued) Expected reactio
Page 227 and 228: Papua New Guinea (continued) Docume
Page 229 and 230: Peru Taxing authority and tax law T
Page 231 and 232: Peru (continued) Frequency of tax a
Page 233 and 234: Philippines (continued) Transfer pr
Page 235 and 236: Poland Taxing authority and tax law
Page 237 and 238: Poland (continued) Transfer pricing
Page 239 and 240: Poland (continued) Return disclosur
Page 241 and 242: 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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