In April 2016, the Russian Federal Tax Service published its first set of transfer pricing audit results in relation to the fiscal year 2012.
By virtue of the Russian transfer pricing audit report, the average of tax assessments was around RUB140million (USD2million). The local tax authorities are allowed to adjust prices within intra-group transactions when non-justifiable tax benefit is revealed, and this ruling has resulted into RUB1.2billion (USD19million) of tax assessments. Moreover, the tax authority have already successfully built up tax information exchange networks with foreign tax authorities. Given this trend, more and more taxpayers were carrying out voluntary transfer pricing adjustments accumulating to a total of nearly RUB30billion (USD460million).
The UK Government announced during its 2015 Budget that, it would introduce a new criminal offence applicable to companies who failed to prevent their agents from criminally facilitating tax evasion.
The main objective of this new company offence aims at overcoming the difficulties in attributing criminal liability to companies for the criminal acts of those who act on behalf of them.
The Commissioner of Hong Kong Inland Revenue Department recently commented on the implementation of BEPS project in Hong Kong, particularly in the area of transfer pricing (TP). The Hong Kong Government regards TP legislation and TP documentation requirements are their top priority. The Commissioner also said that the simplified limitation on benefits (LOB) rule as well as the principle purposes test (PPT) will very likely be the norm for Hong Kong tax treaties in the coming future.
In 2016, the Chinese government has taken various measures in view to increase its foreign direct investment (FDI). Such action led to introduction of numerous tax incentive schemes which are appealing to foreign investors in some industries and sectors. The below summary provides you with the details.