Worldwide transfer pricing reference guide 2014

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Croatia (continued) Documentation requirements (continued) • The transfer pricing method applied, including a description of the data, methods and analysis performed in the process of determining transfer prices, and provide reasons why the particular method was selected; • Assumptions and evaluations used in the process of determining transfer prices (in line with the principle of unbiased transactions), with reference to comparability, functional analysis and risk analysis; • All calculations of transfer pricing based on the selected method (such documentation should enable a comparison with the prices applied by other comparable taxpayers); • Update the transfer pricing documentation from previous years documentation, reflecting adjustments made due to changes in relevant facts and circumstances; and • Provision of additional documents upon which the transfer pricing analysis was based or to which the documentation refers. The taxpayer must maintain the documentation concerning related parties and intercompany transactions. Documentation deadlines There is no specific deadline for the preparation of the transfer pricing documentation prescribed by the legislation. The law requires the transfer pricing documentation to be readily available and be provided to the tax authorities upon their request in a tax audit. The documentation should be in Croatian. Although not prescribed by CIT legislation, in practice the tax authorities start requesting, on a case by case basis, a statement on transfer pricing method applied and/or transfer pricing documentation to be submitted as supporting documentation upon submission of the corporate income tax return (four months after the end of the taxpayer’s fiscal year). Statute of limitations on transfer pricing assessments The general statute of limitations for determination of tax liabilities and rights in a particular tax period expires at the end of the third year following the year in which a tax return should have been filed (e.g., as the 2014 corporate income tax return has to be filed by 30 April 2015, filings for 2014 become statute-barred on 1 January 2019). However, the general statute of limitations may be extended, and starts again after intervention by the tax authority concerning a tax return which has been filed. The absolute statute of limitations expires at the end of the sixth year following the year in which the tax return should have been filed. Therefore, filings for 2014 become statute-barred on 1 January 2022, regardless of the number of intervening events initiated by the tax authority. Note however that the amendments to the law provisions regulating the statute of limitation period of the right to assess tax, are in effect as of 1 January 2013. Based on the new rules, the statute of limitation period mentioned above could be prolonged in cases where investigations are initiated over a director, shareholder or related party in connection to the abuse of rights (e.g., deliberate actions aimed at non-payment of tax) or unexplained sources of assets. Return disclosures/related party disclosures Based on the CIT legislation, no specific disclosures are required in the annual tax return. Transfer pricing–specific returns No specific requirements for a separate return (including an information return) for related party transactions are prescribed by the Croatian legislation. Frequency of tax audit and transfer pricing scrutiny by the tax authority In the past few years, the tax authorities have increased their focus on prices applied in transactions with related parties and thus, the frequency of transfer pricing audits has increased. Initially, due to limited experience in transfer pricing, the tax authorities tend to dispute over service charges between related companies. However, there is a noticeable trend towards an increase in transfer pricing knowledge of tax inspectors and awareness of the transfer pricing issues. Worldwide transfer pricing reference guide 76
Croatia (continued) Frequency of tax audit and transfer pricing scrutiny by the tax authority (continued) In 2009, the tax authorities issued a manual containing the instructions that should be followed by the tax inspectors in transfer pricing audits. The manual also provides a translation of the OECD Guidelines. Therefore, it can be inferred that the tax authorities consider the OECD Guidelines to represent a good theoretical basis for defining transfer prices and for preparing the documentation which supports them. Once a tax audit is initiated, there is a high risk of transfer pricing being reviewed within the audit, especially in cases involving high value related party transactions. APA opportunity Currently, there is no legal basis for APAs in Croatia. Expected reaction to OECD Report on BEPS The Croatian tax authorities have published news on developments with respect to BEPS on their website. However, no official reaction to the Report on BEPS has been released by the Croatian tax authorities. Worldwide transfer pricing reference guide 77
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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
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 and 54: Bulgaria (continued) Return disclos
Page 55 and 56: Cameroon Taxing authority and tax l
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: Croatia Taxing authority and tax la
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
Page 125 and 126: 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
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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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EY | Assurance | Tax | Transactions
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Worldwide transfer pricing reference guide 2014

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