Worldwide transfer pricing reference guide 2014

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Venezuela (continued) Documentation requirements (continued) The documentation requirements include details on the functions, assets, risks, organizational structure, business descriptions, detailed information of all operations with related and non-related parties, audited financial statements, agreements and contracts, reasoned method selection, inventory valuation method (if applicable), analysis results and other relevant information. Documentation deadlines The taxpayer must prepare documentation by the filing date of the annual income tax return at the end of every fiscal year. In addition, the taxpayer must submit the documentation upon request by the SENIAT during a transfer pricing audit. For taxpayers whose fiscal year ends in December, it is mandatory to file PT–99 during June. In other cases, the filing deadline will be six months after the fiscal year end. Statute of limitations on transfer pricing assessments The statute of limitations is four years from the date of filing the return and six years if the taxpayer fails to comply with the filing of any tax return, including returns for income tax, VAT or customs duties. However, PT–99 is not considered a tax return for penalty purposes. Return disclosures/related party disclosures A controlled party’s PT–99 must be filed during the six months immediately following the close of each tax year. The PT–99 form is available on the tax authority’s website (www.seniat.gob.ve). Transfer pricing–specific returns A controlled party’s PT–99 must be filed during the six months, immediately following the close of each tax year. The PT–99 form is available on the tax authority’s website (mentioned above). Frequency of tax audit and transfer pricing scrutiny by the tax authority The SENIAT continues being very active in transfer pricing audits. It has added transfer pricing as a relevant topic to be audited during general tax audits. Thus far, audits have been conducted on taxpayers irrespective of industry. Tax audits have been focused both in formal duties (i.e., request of contemporaneous transfer pricing documentation, filing PT–99) and in the determination of proper taxable income in inter-company transactions (i.e., challenge methodology, comparables, use of multiple year data, segmented financial data by transaction and/or activity, among others). The evaluation criteria to trigger a transfer pricing audit are: • Have inconsistencies between the transfer pricing report, income tax return and the transfer pricing information return • Use non-updated financial information from comparable companies up to June of the fiscal year subject to the study • Have profit level indicators below the interquartile arm’s length range • Show lower operating margins compared with operating margins from prior years or with operating losses • Late filing of transfer pricing information return The risk of transfer pricing scrutiny is high when a taxpayer performs financial operations directly or indirectly with related parties and when taxpayers have technical assistance or know how agreements with related parties abroad. Currently, in the transfer pricing review process, time frame to submit the information requested, ranges between two to three business days and there is reluctance in giving extensions. The likelihood of an annual tax audit in general is high, as is the likelihood that transfer pricing will be reviewed as part of the audit. However, the likelihood that if transfer pricing is reviewed as part of the audit, the transfer pricing methodology will be challenged, is low. APA opportunity Unilateral and bilateral APAs are available to the extent that they are carried out with nations that have concluded double taxation treaties with Venezuela (refer to Income Tax Law Articles 143 to 167, and Master Tax Code Chapter III, Articles 109 to 111 and Articles 220 to 229). Worldwide transfer pricing reference guide 318
Venezuela (continued) Expected reaction to OECD Report on BEPS There have been no recent changes in tax regulations to address the BEPS project. Nonetheless, current transfer pricing regulations do already require some information described in the OECD country by country reporting memo, such as a list of intangible goods which taxpayer owns or uses. Worldwide transfer pricing reference guide 319
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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
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Netherlands (continued) Statute of
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New Zealand Taxing authority and ta
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New Zealand (continued) Frequency o
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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
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
Page 311 and 312: United States (continued) Transfer
Page 313 and 314: Uruguay Taxing authority and tax la
Page 315 and 316: Uruguay (continued) APA opportunity
Page 317: Venezuela Taxing authority and tax
Page 321 and 322: Vietnam (continued) Relevant regula
Page 323 and 324: Vietnam (continued) Documentation d
Page 325 and 326: Zimbabwe Taxing authority and tax l
Page 327 and 328: Zimbabwe (continued) Relevant regul
Page 329 and 330: Transfer pricing contacts Area cont
Page 331 and 332: Jurisdiction contacts • El Salvad
Page 333 and 334: Jurisdiction contacts • Rep. of C
Page 335: EY | Assurance | Tax | Transactions
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Worldwide transfer pricing reference guide 2014

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