Worldwide transfer pricing reference guide 2014

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Cambodia Taxing authority and tax law Taxing authority: General Department of Taxation (GDT). Relevant regulations and rulings Article 18 of the Cambodia Law on Taxation (LOT), Allocation of income and deductions among taxpayers: In the case of two or more enterprises, whether incorporated or organized, in or outside of the Kingdom of Cambodia may distribute gross income, deductions, or other benefits among such enterprises and their owners in order to prevent the avoidance or evasion of taxes or to clearly reflect the income of such enterprises, or their owners. For the purpose of this Article, two or more enterprises are under common ownership, if a person owns 20% or more in value or equity interests of each enterprise. Cambodia has not concluded any double tax agreements as of January 2014. Audit risk/transfer pricing scrutiny There is no specific transfer pricing rule in Cambodia. Under the LOT, the tax regulations provide the tax authority with wide powers to reallocate income and expenditure between taxpayers having 20% or more common ownership. Transactions between related parties may be subject to redetermination by the Cambodian tax authority for the purpose of preventing tax avoidance. Therefore, in order to avoid the tax risk, companies should ensure that all related party transactions are conducted within the arm’s length principle. Worldwide transfer pricing reference guide 54
Cameroon Taxing authority and tax law Tax authority: General Director of Taxation Tax law: General Tax Code Relevant regulations and rulings Circular on the Finance Law by the General Director of Taxation. OECD guidelines treatment Cameroon does not make any specific reference to the OECD Guidelines but refers to the arm’s length principle. Priorities/pricing methods Not applicable. Transfer pricing penalties There are no specific rules for transfer pricing adjustments but generally all tax adjustments are subject to penalties. Penalty relief In case of partial or total failure to submit the required documentation, a notice to provide or complete the documentation will be served within 30 days to the company. This notice should remind the taxpayer of the penalties in case of failure to reply, including adjustments based on information available to the authority. The taxpayer should make all attempts to submit the transfer pricing documentation within the deadline provided i.e., 15 March of each year. Documentation requirements Article 18-3 of the New Finance Law 2014 stipulates that: “Companies falling under the Department in charge of large enterprises shall also submit within the same deadline and using the form provided by the Administration, the statement of shares which they own in other companies where such shares do not exceed 25% of their share capital. They shall attach a detailed statement of transactions with the companies which control them or which are under their control, be they in Cameroon or abroad. For the application of this provision, the notion of control must be understood as used in Article M 19 (a) (2) of the Tax Procedures Manual.“ The documents to be included in the annual tax return are: A statement of ownership in other companies if the ownership exceeds 25% of their share capital. The statement should be accompanied by the following elements: • A general description of the ownership, including changes in securities occurred during the last two years of activities • A general description of the legal and operational structures of the associated companies, including an identification of the associated structures engaged in transactions with the company • A general description of the functions performed and risks assumed by the associated companies that affect the company and its business reporting • A list of key intangible assets, including patents, trademarks, trade names and know-how related to the company filing the return A detailed statement of the intra-group transactions: • A description of transactions with other affiliates, including the nature, amount of flows, and fees Worldwide transfer pricing reference guide 55
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Worldwide Transfer Pricing Referenc
Page 3 and 4: Worldwide transfer pricing referenc
Page 5 and 6: Nigeria 215 Norway 217 Oman 220 Pak
Page 7 and 8: The content is current as of 28 Feb
Page 9 and 10: CUP (comparable uncontrolled price)
Page 11 and 12: Albania (continued) Priorities/pric
Page 13 and 14: Algeria Taxing authority and tax la
Page 15 and 16: Algeria (continued) Return disclosu
Page 17 and 18: Angola (continued) Transfer pricing
Page 19 and 20: Argentina Taxing authority and tax
Page 21 and 22: Argentina (continued) Transfer pric
Page 23 and 24: Australia Taxing authority and tax
Page 25 and 26: Australia (continued) Priorities/pr
Page 27 and 28: Australia (continued) Documentation
Page 29 and 30: Australia (continued) Frequency of
Page 31 and 32: Austria (continued) Documentation r
Page 33 and 34: Bahrain Taxing authority and tax la
Page 35 and 36: Bangladesh (continued) Penalty reli
Page 37 and 38: Belgium Taxing authority and tax la
Page 39 and 40: Belgium (continued) Statute of limi
Page 41 and 42: Bolivia Taxing authority and tax la
Page 43 and 44: Botswana Taxing authority and tax l
Page 45 and 46: Brazil (continued) Relevant regulat
Page 47 and 48: Brazil (continued) Priorities/prici
Page 49 and 50: Brunei Taxing authority and tax law
Page 51 and 52: Bulgaria (continued) Transfer prici
Page 53: Bulgaria (continued) Return disclos
Page 57 and 58: Canada Taxing authority and tax law
Page 59 and 60: Canada (continued) Documentation re
Page 61 and 62: Chile Taxing authority and tax law
Page 63 and 64: Chile (continued) Return disclosure
Page 65 and 66: China (continued) Documentation req
Page 67 and 68: Colombia Taxing authority and tax l
Page 69 and 70: Colombia (continued) Penalty relief
Page 71 and 72: Republic of Congo Taxing authority
Page 73 and 74: Costa Rica Taxing authority and tax
Page 75 and 76: Croatia Taxing authority and tax la
Page 77 and 78: Croatia (continued) Frequency of ta
Page 79 and 80: Czech Republic Taxing authority and
Page 81 and 82: Denmark Taxing authority and tax la
Page 83 and 84: Denmark (continued) Documentation d
Page 85 and 86: Dominican Republic Taxing authority
Page 87 and 88: Dominican Republic (continued) Expe
Page 89 and 90: Ecuador (continued) Priorities/pric
Page 91 and 92: Ecuador (continued) Return disclosu
Page 93 and 94: Egypt Taxing authority and tax law
Page 95 and 96: Egypt (continued) Frequency of tax
Page 97 and 98: El Salvador (continued) Transfer pr
Page 99 and 100: Estonia Taxing authority and tax la
Page 101 and 102: Fiji Taxing authority and tax law T
Page 103 and 104: Fiji (continued) Frequency of tax a
Page 105 and 106:
Finland (continued) Documentation r
Page 107 and 108:
France (continued) Transfer pricing
Page 109 and 110:
France (continued) Documentation re
Page 111 and 112:
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
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Greece (continued) Transfer pricing
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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
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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 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
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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
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 and 260:
Senegal (continued) Documentation r
Page 261 and 262:
Serbia Taxing authority and tax law
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
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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 and 318:
Venezuela Taxing authority and tax
Page 319 and 320:
Venezuela (continued) Expected reac
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
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Jurisdiction contacts • Rep. of C
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Worldwide transfer pricing reference guide 2014

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