On 12th July 2013, the Ministry of Finance issued the Rulebook on transfer pricing and arm’s length methods applicable to determination of prices in related-party transactions (“Rulebook”). The Rulebook implements the provisions of the Corporate Income Tax Law (“Law”) on transfer pricing, introduced in December 2012. According to those provisions, mandatory transfer pricing documentation has to be filed along with the tax balance sheet.
Deadline for filing of the tax balance sheet has been extended to 180 days from the end of the relevant tax period. For FY 2013, tax balance sheet should be filed until 30th June 2014. The Law also introduced the possibility of applying transactional transfer pricing methods (TNMM and PS) in addition to the already existing traditional transfer pricing methods (CUP, C+ and R-). Read more
