Worldwide transfer pricing reference guide 2014

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Senegal (continued) Return disclosures/related party disclosures Currently, the corporate income tax return does not include a transfer pricing schedule to be completed or specific transfer pricing related questions. Transfer pricing–specific returns There is no specific transfer pricing return. Frequency of tax audit and transfer pricing scrutiny by the tax authority The tax authorities may conduct a transfer pricing audit any time during the year. In general transfer pricing is frequently audited by the Senegalese Tax Authorities. APA opportunity Not applicable in Senegal. Expected reaction to OECD Report on BEPS There has not been any reaction from the tax authorities up until January 2014. Worldwide transfer pricing reference guide 260
Serbia Taxing authority and tax law Tax authority: Serbian Ministry of Finance Applicable tax legislation: • Corporate Income Tax Law (CIT Law) • Rulebook on transfer pricing and methods for the determination of arm’s length prices in intra-group transactions (Rulebook) Relevant regulations and rulings Articles 59 through 61a of the CIT Law define the arm’s length principle, the acceptable methods and obligation to prepare and file transfer pricing documentation. The Rulebook provides further details on these, and also prescribes obligatory content of the transfer pricing documentation. OECD Guidelines treatment Serbian transfer pricing provisions and documentation requirements are generally based on the OECD Guidelines. Serbian transfer pricing rules do not contain any specific provisions in relation to business restructurings. Priorities/pricing methods Taxpayers may choose any of the defined traditional transaction methods (CUP, Cost Plus and Resale Minus) and transactional profit based methods (TNMM and Profit Split method). There is no priority in the selection of methods. The taxpayer is also allowed to use any other unspecified method which is reasonable to apply in a given circumstance assuming that the specified methods cannot be applied. Transfer pricing penalties A penalty of approximately EUR20,000 can be imposed if the taxpayer fails to disclose related party transactions in the annual CIT return or does not prepare and file transfer pricing documentation by the prescribed deadlines. In addition, the possible adjustment of taxable income on transfer pricing basis may result in penalty of up to 20% of the understated tax liabilities and may further result in increased interest for late tax payments. Penalty relief There is no penalty relief available, however, taxpayers may be permitted an additional period of up to 90 days to comply with transfer pricing documentary requirements (i.e., to submit to the tax authorities the prescribed transfer pricing document). Documentation requirements Starting FY2013 all taxpayers are obliged to prepare transfer pricing documentation that needs to contain mandatory elements and file it along with the annual CIT return. The prescribed elements of the transfer pricing documentation are: • Analysis of the group • Industry analysis • Functional analysis • Selection of transfer pricing method • Conclusions reached • Appendices Currently, there is no materiality threshold for transactions or other conditions prescribed which would exclude or limit the general scope of transfer pricing documentation in particular cases. Worldwide transfer pricing reference guide 261
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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
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India Taxing authority and tax law
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India (continued) Documentation req
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Indonesia Taxing authority and tax
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Indonesia (continued) Frequency of
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Ireland Taxing authority and tax la
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Ireland (continued) Frequency of ta
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Israel (continued) Priorities/prici
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Italy Taxing authority and tax law
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Italy (continued) Transfer pricing
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Italy (continued) Frequency of tax
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Japan (continued) Transfer pricing
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Japan (continued) APA opportunity U
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Kazakhstan Taxing authority and tax
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Kazakhstan (continued) Frequency of
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Kenya (continued) Documentation req
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Kosovo (continued) Documentation re
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Kuwait (continued) Documentation re
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Latvia Taxing authority and tax law
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Lebanon Taxing authority and tax la
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Lithuania Taxing authority and tax
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Luxembourg Taxing authority and tax
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Former Yugoslav Republic of Macedon
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Malaysia Taxing authority and tax l
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Malaysia (continued) Frequency of t
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Maldives (continued) Statute of lim
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Malta (continued) Return disclosure
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Mauritius (continued) APA opportuni
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Mexico (continued) Transfer pricing
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Mexico (continued) Return disclosur
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Montenegro (continued) Frequency of
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Morocco (continued) Transfer pricin
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Myanmar Taxing authority and tax la
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Namibia Taxing authority and tax la
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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
Page 243 and 244: Portugal (continued) Transfer prici
Page 245 and 246: Portugal (continued) APA opportunit
Page 247 and 248: Qatar (continued) OECD guidelines t
Page 249 and 250: Qatar (continued) Return disclosure
Page 251 and 252: Romania (continued) Documentation r
Page 253 and 254: Russian Federation Taxing authority
Page 255 and 256: Russian Federation (continued) Freq
Page 257 and 258: Saudi Arabia (continued) Transfer p
Page 259: Senegal (continued) Documentation r
Page 263 and 264: Singapore Taxing authority and tax
Page 265 and 266: Singapore (continued) Frequency of
Page 267 and 268: Slovak Republic (continued) Documen
Page 269 and 270: Slovenia Taxing authority and tax l
Page 271 and 272: Slovenia (continued) Transfer prici
Page 273 and 274: South Africa (continued) Penalty re
Page 275 and 276: South Korea (Republic of Korea) Tax
Page 277 and 278: South Korea (Republic of Korea) (co
Page 279 and 280: Spain (continued) Penalty relief So
Page 281 and 282: Spain (continued) APA opportunity T
Page 283 and 284: Sri Lanka (continued) Return disclo
Page 285 and 286: Sweden (continued) Documentation re
Page 287 and 288: Switzerland Taxing authority and ta
Page 289 and 290: Taiwan Taxing authority and tax law
Page 291 and 292: Taiwan (continued) Return disclosur
Page 293 and 294: Tanzania Taxing authority and tax l
Page 295 and 296: Thailand Taxing authority and tax l
Page 297 and 298: Thailand (continued) Frequency of t
Page 299 and 300: Turkey (continued) Priorities/prici
Page 301 and 302: Uganda Taxing authority and tax law
Page 303 and 304: Ukraine Taxing authority and tax la
Page 305 and 306: Ukraine (continued) Transfer pricin
Page 307 and 308: United Kingdom Taxing authority and
Page 309 and 310: 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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