New Zealand – new transfer pricing and permanent establishment rules proposed

CountrySummary-NewZealand At the beginning of March 2017, the New Zealand Government released three consultation papers proposing new measures to strengthen New Zealand’s rules for taxing large multinationals.  These three consultation papers addressed: Transfer pricing and permanent establishment avoidance; Strengthening our interest limitation rules; and New Zealand’s implementation of the multilateral convention to implement tax treaty related […]

Offshore marketing hubs under the ATO’s lens

pastedImage Introduction On 16 January 2017, the Australian Taxation Office (“ATO”) released its Practical Compliance Guideline (“Guideline”) which outlines the ATO’s compliance approach to transfer pricing issues relating to centralised operating models involving procurement, marketing, sales and distribution functions (referred to as offshore “hubs”).  The Guideline is effective 1 January 2017 and applies to new and […]

Major developments for taxpayers in Indonesia

CountrySummary-Indonesia Overview A new Ministry of Finance (“MOF”) Regulation No. 213/PMK.03/2016 (“MoF-213”), which was issued and became effective on 30th December 2016, will have profound transfer pricing implications for taxpayers in Indonesia.  The MoF-213 requires companies that meet certain criteria to maintain three tiers of transfer pricing documentation: Master file – providing a high level overview […]

TP decree amended to cover intangible assets

CountrySummary-Vietnam Tu Ha, Director of Quantera Global based in Vietnam, was interviewed by Vietnam Investment Review on the release of the new draft TP Decree and implications for taxpayers in Vietnam, specifically relating to intangible assets.  See attached for a full transcript of the interview, published on 2 January 2016. For further insight on the same topic, […]