Transfer Pricing

Transfer pricing rules South Africa’s (SA) transfer pricing (TP) rules are contained in Section 31 of the Income Tax Act of 58 of 1962 (ITA) and are supported by Practice Note 7, which provides additional guidance to taxpayers on determining an arm’s length consideration in relation to cross border related party transactions. SA TP rules […]

Transfer pricing rules The Inland Revenue Authority of Singapore (IRAS) released the first Transfer Pricing (TP) guidelines in 2006 and its 6th edition Transfer Pricing Guidelines (TPG) on 10 August 2021. The revised TPG guides the implementation of the transfer pricing (TP) related amendments made to the Income Tax Act (ITA) on 26 October 2017. […]

Transfer pricing rules The Japanese transfer pricing (TP) legislation is in Article 66-4 of the Act of Special Measures Concerning Taxation and is based on the arm’s length principle as per Article 9 of the OECD Model Tax Convention on Income and Capital, i.e. it follows the OECD Guidelines updated in July 2022. The TP […]

Transfer pricing rules China’s transfer pricing (TP) legislation includes the Corporate Income Tax Act (2007) Part 6 and a litany of law-equivalent tax bulletins and announcements from 2017 onward. The legislation is based on the arm’s length principle throughout, the description of which is highly similar to the OECD Guidelines; yet OECD is not mentioned […]

Transfer pricing rules Australia’s transfer pricing legislation is contained in Division 815 of the Income Tax Assessment Act 1997 (‘ITAA 1997’) and subdivision 284-E of the Taxation Administration Act 1953 (‘TAA 1953’). The legislation is intended to be interpreted to achieve consistency with the Organisation for Economic Co-Operation and Development (‘OECD’) Transfer Pricing Guidelines for […]

Transfer pricing rules The US transfer pricing (TP) statute is expressed in the Internal Revenue Code in Section (IRC) 482. The US TP rules apply to all taxpayers, including US branches of overseas companies. The US TP rules generally authorize the Internal Revenue Service (‘IRS’) to allocate income, deductions, credits, and allowances among related business […]

Transfer pricing rules Canada’s transfer pricing law, Section 247 of the Income Tax Act (ITA), received Royal Assent on June 18, 1998. The transfer pricing rules apply to Canadian taxpayers and partnerships who transact with foreign-related parties and contain no materiality threshold or exemptions. The CRA provides significant specific transfer pricing guidance through transfer pricing […]