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Proposed change to the transfer pricing documentation rules

2016/02/11

In the 2016 tax reform proposal, an amendment to the transfer pricing documentation rules was introduced. The proposal is to make the transfer pricing documentation rules consistent with BEPS Action Plan 13.

Group taxation

2016/01/08

A 100%-controlled group with a domestic parent company is allowed to file a consolidated tax return for national corporate income. The consolidated filing system cannot be used though, when the parent company is a foreign company. Where a 100%-controlled group does not file a consolidated tax return, there are a few special rules on transactions betweendomestic members.