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LayoutTransfer Pricing News Welcome to the second edition of This issue contains transfer pricing Transfer Pricing News.
updates from a number of countriesacross the globe – a necessity in the global economy we all now inhabit. So if you want to know about new developments in transfer pricing aroundthe world this is the place to look.
To find out more about the topics featured in Transfer Pricing News do not hesitate to get in touch with theGrant Thornton transfer pricing team.
Their contact details are included on thelast page of this newsletter. This information has been provided by member firms within Grant Thornton International Ltd, and is for informational purposes only. Neither the respective member firm nor Grant Thornton International Ltd can guarantee the accuracy, timeliness or completeness of the data contained herein. As such, you should not act on the information without first seeking professional tax advice.
Transfer Pricing News No. 2: August 2012
Revised thin capitalisation rules
Interest related to bonds issued by Example for treasury companies:
public offering or loans granted by capitalisation (thin cap) banks and financial institutions are Interest paid on interco debt: 50,000.00
excluded from the thin cap rule. introduced in Belgian tax law from In order to safeguard the Belgian Interest received from interco in framework of cash pooling agreement: 10,000.00
1 July 2012. Until 30 June 2012, a 7:1 group financing companies an debt to equity ratio was in place for amendment on the new thin cap rule Total interco debt: 900,000.00
interest paid or attributed to beneficial will be introduced. owners subject to a tax regime which An exception would be applicable Paid in capital plus taxed reserves: 100,000.00 (x5 = 500,000.00)
was far more beneficial than the for Belgian companies involved in Belgian tax regime. Interests paid or centralised treasury management (for Non-deductible interests: 50,000.00 – 10,000.00 = 40,000.00: (400,000.00/900,000.00) = 17,600.00
attributed that exceeded the applicable example cash pooling). The thin cap ratio were to be considered non- rules on the 5:1 intercompany debt to deductible for Belgian income tax equity ratio would be applicable on a It is advisable for Belgian group net basis (i.e. the positive difference companies to revise their intercompany The thin cap rules have now been between, on the one hand, the interests debt – equity ratio in order to avoid broadened in two ways: paid or attributed on intercompany future adverse tax consequences. On • the debt to equity ratio has lowered debts and, on the other hand, the the other hand a beneficial exemption interests received related to funds put will be applicable on the thin cap • besides interest paid or attributed at the disposal of group companies regime for group treasury companies. to beneficial owners subject to a within the frame work of the global beneficial tax regime, the rule will cash pooling agreement). also be applicable to all interest Grant Thornton Belgium paid or attributed to affiliatedcompanies. Transfer Pricing News No. 2: August 2012
China issue Advance Pricing
New development of China APA
Supplementary provisions of renewal
Protection of taxpayers' rights
Arrangement Annual Report (2010)
In the newly issued 2010 annual report, Another important development in the On 12 April 2012, the In 2010 the Chinese tax authorities the SAT for the first time clarifies that 2010 annual report is that it has added State Administration of concluded and signed four unilateral the enterprise's profit level should not a new chapter on the protection of Taxation of China (SAT) APAs and four bilateral APAs. This is be lower than the median regarding the taxpayers' rights. In this chapter, it issued the China Advance Pricing the second fruitful year in which renewal of APAs. It is required that defines the confidentiality of taxpayers' Arrangement Annual Report (2010) bilateral APAs were signed. From ‘during the term of the APA, if the information and taxpayers' freedom of (the 2010 annual report). This is the 1 January 2005 to 31 December 2010, enterprise's overall profit level stays concluding an APA. The report second advance pricing arrangement the Chinese tax authorities received 73 below the median most of the time, especially points out: ‘in cases where (APA) annual report issued by the written requests or formal applications where an arm's length range is used, the tax authority and the enterprise fail SAT, after the 2009 annual report was for bilateral APAs. The countries the tax authority may no longer accept to reach an agreement for an APA, the first released. The 2010 annual report involved include Japan, Korea, the an application for renewal of the APA'.
non-factual information of the has followed the same framework with United States, Denmark and Singapore.
enterprise, such as various suggestions, a new chapter on the protection of In addition, the SAT has received inferences, ideas and conclusions taxpayers' rights (chapter IV) and some numerous enquiries on bilateral APAs obtained by the tax authority during revisions in Chapter III.
from enterprises. It is expected that the discussions and negotiations shall not number of APA applications will be used in future tax investigations of continue to increase.
the transactions covered by theproposed APA'. This chapter can beregarded as an indicator that the SATaims to eliminate the concerns of thetaxpayers and encourage them to applyfor APAs.
Transfer Pricing News No. 2: August 2012
1. Statistics of APAs by calendar year
applications and concluded APAs.
review and negotiation process within The 2010 annual report includes the and phase
However, the percentage of accepted 12 months for unilateral APAs and official statistics on in-process and signed The number of unilateral APAs is applications involving the transfer or use within 24 months for bilateral APAs.
APAs for the period from 1 January decreasing year by year, while the number of intangible assets and the provision of 2005 to the end of 2010. The following of bilateral APAs is generally increasing.
services is increasing significantly, and 4. APAs by transfer pricing method
trends are reflected from the data: From 2005 to 2008, more unilateral than the total percentage has exceeded that of TNMM is the most commonly used • as an effective way to avoid bilateral APAs were signed each year.
APAs involving the purchase and sale of transfer pricing method among the international double taxation, a However, the number of bilateral APAs tangible assets. It is anticipated that the signed APAs (64%), with the second bilateral APA is becoming more and exceeded that of unilateral APAs in 2009 percentage of APAs involving types of most popular transfer pricing method more popular among taxpayers for the first time, representing the APA transactions other than the purchase and being the cost plus method. The report • the number of APAs related to programme's principal component. In sale of tangible assets will increase year also points out however that the intangible assets or services or 2010, the number of bilateral APAs signed Chinese tax authority hopes that finance is increasing rapidly was equal to that of unilateral APAs. This enterprises will cooperate more • the processing time of most signed indicates that taxpayers are attaching 3. APAs by processing time
effectively with tax officers during the APAs is less than two years, the more importance to bilateral APAs and China's unilateral APAs were all APA review and evaluation phase to efficiency is expected to increase looking for ways to resolve bilateral completed in two years or less, with provide sufficient information regarding gradually in the future international transfer pricing issues and 53% completed within one year and transactions and prices so that the resale • more than half of the signed APAs avoid double taxation through the mutual 47% taking between one and two years.
price method and the profit split method applied the transactional net margin agreement procedure (MAP) process. It While bilateral APAs generally take may be more frequently applied in the method (TNMM) as the transfer also reflects the SAT's intensified effort in more time, many were completed within APA programme.
pricing method, but the application promoting the MAP program.
one year (56%); 19% took between one of other reasonable methods is to two years, 19% took between two to Rose Zhou
encouraged by the SAT. 2. APAs by transaction types
three years, and the remaining 6% were Grant Thornton China Purchase and sale of tangible assets completed in more than three years. It is Some important statistics charts are accounts for the largest portion (64%) of also pointed out that the Chinese tax extracted as follows: transactions covered by accepted authorities generally aim to complete the Transfer Pricing News No. 2: August 2012
Attribution of profits to permanent
The amendment is linked to As a result the profit allocation • the taxable total income of all PEs considerations of the OECD regarding between the head office and the PE including the head office could differ From 1 January 2013, the Authorised OECD-Approach which has been executed currently as from the overall result of the entire new German legislation (AOA) which provides guidance for the profit split will be changed company (potential consequences intends to amend section attribution of profits to PEs. The fundamentally. Examples include: include double taxation or double one of the German Foreign Transaction attribution of profit is ultimately • if a PE provides fictitious services to Tax Act (AStG). In particular the new essential to determine which part of the its head office in another country the • a so called ‘transfer of functions' rules concern cross border transactions earnings will be taxed by the resident PE may be taxed on the basis of may be assumed between PEs of a between head offices and permanent country of the PE according to the revenues including a mark up company being resident in different establishments (PE) for which the arm's relevant double tax treaty.
• profits could also be taxed at the length principle shall be applicable in the According to the new rules a PE level of the PE although the entire shall be treated as an autonomous and company generates losses. The The new rules will apply to independent company in relation to the prerequisite of actual realisation Grant Thornton Germany German companies with PEs abroad headquarters and other PEs (separate of profits would no longer apply.
as well as foreign companies with PEs entity approach).
This could lead to cash issues in Germany. Representatives' PEs will Despite the fact that a company also be affected.
cannot conclude legally bindingcontracts with its (legally dependent)PE, contractual relationships shall beassumed for the tax treatment of crossborder transactions between head officesand their PEs.
Transfer Pricing News No. 2: August 2012
Winds of change in the Indian
The key highlights of the APA are as • the APA shall not be transfer pricing regulations
An APA will enable the taxpayer to binding/annulled if there is change in To address the year-on- attain certainty in advance with respect to • the APA route will enable the law or if the taxpayer has signed the year rapid escalation in determining the arm's length price (ALP) taxpayer to use any method other APA with the CBDT based on transfer pricing disputes or the manner/methodology in which it than one of the prescribed five misrepresentation of facts. CBDT and to address the current need of shall be determined. APAs would be methods available. This will enable will annul in this case by way of an ‘corporate India', the Union Budget applicable for all taxpayers who have the taxpayer to negotiate an 2012 introduced the dispute resolution international transactions and fall within economic method or put across a • once the APA is concluded, then the mechanism, the Advance Pricing the ambit of Indian TP legislation. business rationale to explain the taxpayer is required to file revised Agreement (APA) scheme. This Currently the Budget has only proposed transfer price return(s) with the assessing officer mechanism is a significant and welcome encapsulated the broad framework of an • the APA can be applied for a period (income tax department) who has to change after the gamut of transfer APA. The Central Board of Direct Taxes of five consecutive previous years complete the assessment/ pricing issues that have arisen since (CBDT) has been empowered to frame a • the APA has binding force only on reassessment within one year from the introduction of the regulations a scheme for APAs. Therefore, the finer the taxpayer with whom it is signed the end of the financial year in which details of the APA regime will follow.
and in respect of the relevant the revised return is filed Another surprise in the Union Until such detailed notification and international transaction vis-à-vis the • there is no threshold prescribed for Budget 2012, is that certain specified guidelines are issued, the taxpayers will jurisdictional commissioner of accessing the APA route.
domestic transactions will now fall have to wait to access the APA route.
under transfer pricing (TP) regulations Further the revenue department is increasing the compliance burden of the prepared with field formations and the taxpayer. This article aims to give a brief APA directorate is expected to be based heads up on these two key amendments. in Delhi with facilitation desks inMumbai and Bangalore.
Transfer Pricing News No. 2: August 2012
With this backdrop of APA provisions are certain considerations which the also in conformity with the entire disallow expenses or rework the in the Union Budget 2012, there is food taxpayer needs to ponder before actually quantum of tax holiday being claimed for thought on certain key issues, for firming up on the APA route. While Readers can contact the authors of where the transactions are undertaken getting into an APA, the taxpayer would this article for examples/case studies with related parties. The proposal seeks • the APAs would be need to provide a great degree of highlighting when it would be advisable to strengthen these provisions by information which would involve not to enter into an APA.
bringing them under the TP provisions. • they would encourage a pre-filing only information on past positions but Companies would have to maintain also information regarding the forecasts Specified domestic transactions
TP documentation for such domestic • rollbacks would be permitted and future plans of the taxpayer. How As mentioned above, another interesting transactions between related parties and • there would be APA filing fees confidential or protected this makeover to the Indian TP regulations would also need to determine the • an independent agency to monitor information would be is key to whether introduced in the Union Budget 2012, is appropriate arm's length price. Such and implement this would be the APA regime's successful or not. The that specified domestic transactions will regulations would not be unique to taxpayer needs to gain confidence that now be governed by TP regulations.
India. There are many countries that • an industry representative would this will not be shared with the transfer Specified domestic transactions would mandate compliance requirements for also be a member of the APA office pricing officers. Also one will need to include transactions entered into by domestic transactions within their TP consider the time cost involved in an domestic related parties or by an regimes like the UK, the Netherlands, APA vis-à-vis regular litigation option undertaking with other undertakings of and Malaysia for example.
All these factors are yet to be and whether both can go on in parallel.
the same entity for the purposes of With this widening of the TP ambit, understood. However, broadly the Another important consideration would section 40A, Chapter VI-A, section TP will not be limited to just the multi- scheme should be such that it acts as an be the type of transaction and issues 10AA and which exceed a monetary national companies. Many mid-sized overall progressive catalyst to resolve involved. In case of high value threshold of Rupees 5 crore in aggregate groups, partnership firms, Hindu transfer pricing disputes.
transactions or complex issues, it would during a financial year (approximately Undivided Families and even individuals The detailed APA process is yet to make sense for a taxpayer to opt for an USD 900,000).
will now have to comply with the TP be notified and the finer aspects are in APA especially a bilateral one to ensure ‘The Act' already has provisions the realm of speculation however, there that the foreign country authorities are which empower the assessing officer to Transfer Pricing News No. 2: August 2012
This move by the government is This change in law was fallout from a standard. However, with most of the TP policy applying the prescribed TP aimed at curbing the tax arbitrage thought-provoking Supreme Court case profit based incentives having been methods and maintain mandatory TP opportunity which was available to a of Commissioner of Income Tax IV, phased out the amendment seems to be documentation. They would also be taxpayer in certain cases. On availability Delhi, vs GlaxoSmithKline Asia (P) Ltd misdirected leading to unnecessary required to obtain and file form 3CEB of such tax arbitrage opportunity, the (SLP (Civil) no 18121/2007) wherein the compliance burden on the taxpayer.
with the assessing officer. The taxpayer would accordingly set the court observed that the domestic TP A noticeable change has also been amendments also propose a levy of 2% transfer price between its related regulations are limited to cross-border proposed in section 40A(2)(b) of ‘the penalty each on non-reporting of a domestic entities. The examples of such transactions only and it should be Act', which proposes to expand the transaction, non-maintenance and non- arbitrage opportunity would include the widened to include the domestic related persons definition to include furnishing of documentation. transactions so as to enable the assessing companies where substantial interest is With such augmentation in the • shifting of profits between a loss- officers to ascertain the value of held by the same company.
decade long TP regulations, it is making entity and a profit-making transactions which are required to be However, it should be noted that the expected that tax authorities will now entity to achieve an overall reduced undertaken at market price. Therefore, it specified domestic transactions would be more pragmatic in assessing the was suggested that the law be amended not be covered by the APA scheme.
taxpayers and in consequence the • profit shifting between companies to align the provisions governing While the APA regime has been taxpayers can look forward to reduced that operate units in special domestic transactions between related introduced with respect to international litigation and disputes in India.
economic zones and put the bulk of parties with the provisions of the transactions, the same benefit has not their profits in these to take domestic TP regulation.
been extended in cases of domestic advantage of the tax holidays The proposed change is aimed at transactions thereby increasing the Grant Thornton India strengthening the existing provisions in compliance burden on companies. • profit shifting to an entity enjoying most of the tax holiday schemes and also The new provisions with respect to tax concessions under an incentive provisions which prohibit excessive domestic transactions would be effective scheme could also be achieved payments to related persons from being from 1 April 2012 (after the Finance Bill through pricing of transactions of claimed as tax deduction by putting the is passed by parliament and it receives such entity with another related onus on the taxpayer to maintain and the Presidential assent). The taxpayer company not enjoying such benefits.
report the adherence to the arm's length would need to determine an arm's length Transfer Pricing News No. 2: August 2012
Transfer pricing legal cases
correction notice received in 2006 from It used to be said that Takeda Pharmaceutical Co., Ltd.
the ORTB on the Prevacid transactions.
there were not many In 2008, software provider Adobe The Takeda case recorded the biggest The original reinvestigation process had transfer pricing legal Systems won an appeal to the Tokyo assessment amount in Japan. The most previously been placed on hold so that cases being fought in the Japanese High Court. One of the most important important point of controversy was if Takeda could seek relief through the courts. Following the aggressive transfer points of this controversy is ‘control exist in 50:50 joint ventures'. In Mutual Agreement Procedure (MAP), pricing assessments by the National Tax ‘commissionaire'. The NTA had made April 2012, Takeda received notice that however, the MAP did not result in any Agency (NTA), many more cases are an assessment using secret comparables the Osaka Regional Tax Bureau (ORTB) agreement between the tax authorities of now emerging. The NTA are so far not and characterising Adobe's Japanese had concluded the reinvestigation with a Japan and the United States. Takeda has always successful.
subsidiary as a full-fledged buy-sell decision to reduce the original been asserting the legitimacy of the software distributer. Adobe took the assessment of JPY 122.3 billion in Takeda position to the ORTB.
position that the proper risk profile for taxable income by the amount of In May 2012, Takeda submitted a transfer pricing purposes was a JPY 97.7 billion. As a result, Takeda new request for reconsideration to the marketing service provider. The NTA's expects to receive a refund of JPY 57.1 Osaka Regional Tax Tribunal, assessment was upheld by the Tokyo billion, tax and interest combined.
petitioning for the cancellation of the District Court, but was overturned by The subject transactions were portion of the original correction that the Tokyo High Court. Japan's tax between Takeda and TAP still remains after the conclusion of authority decided not to appeal.
Pharmaceutical Products Inc (TAP) a ORTB's reinvestigation. The point of 50-50 joint venture between Takeda and controversy ‘50:50 joint venture' will be Abbott Laboratories. In November discussed further.
2011, Takeda re-opened a suspendedreinvestigation process concerning the Transfer Pricing News No. 2: August 2012
Recent transfer pricing assessments
2010 – Hewlett-Packard Japan, Ltd.
On 1 February 2010 a National tax Details of some of the adjustments that Hewlett Packard's Japanese subsidiary tribunal decision, reversed JPY 14.1 have been made by the tax authorities, (HP Japan) received a notice of billion of a JPY 21.3 billion revenue along with related issues regarding assessment from the Tokyo regional tax reassessment against TDK Corporation disputes with the tax authorities, have bureau (TRTB) for the two years been published from time to time. The through October 2006 for expenses paid The subject transactions were following is a recent and hugely to its US parent. TRTB said that it was electronic parts transactions with foreign publicised example.
not evident for what services these affiliates in Hong Kong and the expenses had been paid to its parent and were presumed to be recognised by the This result was interesting in itself as TRTB as a donation (taxable income), it's extremely rare for a taxpayer to and therefore not deductible under the succeed in an appeal to the National tax domestic donation provisions. The tribunal on purely transfer pricing adjustment to income was JPY 47 grounds. Additionally, the size of the reduction in favour of TDK was alsosignificant. Toshiya Kimura
Grant Thornton Japan Transfer Pricing News No. 2: August 2012
Amendments to the Netherlands
When a holding company also has an Transfer pricing studies including The average process time for both limitation of interest deduction rules
active group financing function, loans debt capacity analysis and interest rate APA and ATR requests has improved in The parliament's lower which are used to actively finance group benchmarking remain necessary to 2011. It took an average of 41 days (47 house approved a bill to companies are the exception to this rule.
support the arm's length nature of days in 2010) to process an APA and an limit the deductibility of Further exception is provided in the case interest rates.
ATR request in 2011. ATR requests can interest relating to the financing of a that the acquisition price relates to be handled more quickly than APA particular category of holding expansion of operational activities of a Netherlands Advance Pricing
requests (with an average process time of companies for Dutch corporate income Agreement (APA) statistics
36 days). Almost 60% of the combined tax purposes. Accordingly, the The first EUR 750,000 of excessive The Dutch tax authorities completed APA and ATR requests is an ATR deduction of excessive interest on loans, interest is always deductible in order to 248 (205 in 2010) APAs and granted 408 taken up for investment in participations limit the administrative burden.
(355 in 2010) advance tax rulings (ATRs) In general, the Dutch tax authorities qualifying for the ‘participation A grandfathering rule is included in in 2011, which was an increase from handle requests within two months and exemption' would not be allowed. the bill. Under this rule, taxpayers may previous years in both cases. the Netherlands does not charge APA The excessive interest is determined elect to disregard 90% of the acquisition Besides granting 248 APAs, seven annually by dividing the amount of the price with respect to acquisitions in (zero in 2010) requests were denied and participation debt by total loans, and taxable years that commenced on or 64 (67 in 2010) requests were either Michiel van den Berg
multiplying this amount by the total before 1 January 2006.
withdrawn or not completed.
Grant Thornton Netherlands annual interest owed. The participation The legislation would apply to Although the Netherlands debt equals the positive difference financial years beginning on or after 1 concluded numerous bilateral and between the aggregate historic cost price January 2013. The Dutch cabinet also multilateral APAs, unilateral APAs of qualifying investments and the fiscal supports abolishing the Dutch thin remain in the majority.
equity of the taxpayer. Transfer Pricing News No. 2: August 2012
Controlled Foreign Companies (CFCs)
Should the foreign subsidiary not Revision to HMRC manual – group
The HMRC manuals have been meet the conditions under the gateway, loss relief
updated to confirm that it interprets the In the April 2012 edition then they will have to consider the Previously, the UK tax legislation relevant legislation widely, and will of this newsletter, the general CFC provisions. This will permitted claims for relief to be made accept revised claims for relief by group draft CFC legislation that require the subsidiary to identify the within the 12 month period following an companies as a consequence of a MAP had been released was outlined. The final assets and risks of the company in the agreement under the Mutual Agreement settlement, even if the claims relate to a CFC legislation has now been published UK pertaining to the subsidiary and Procedure (MAP). The legislation did closed year.
as part of the Finance Bill 2012.
identify the extent to which significant not clarify whether the ability to amend The amendment to the international The new gateway test has been people functions associated with those the claims is restricted to the party to the manual is welcome as it removes an simplified to ensure that the taxpayers assets and risks are carried out in the UK MAP, or whether it extends more widely element of uncertainty for UK are able to identify more easily, whether by the company.
to encompass, for example, group taxpayers. More widely the HMRC a foreign subsidiary's profits are within companies that may wish to revise their manuals, which are directed at the scope of the new rules. This should group relief claims following MAP inspectors of taxes but are widely used potentially benefit a large number of by taxpayers as a guide for HMRC companies, which will not need to thinking, are being reviewed and consider other chapters beyond the updated. We will provide updates in gateway chapters.
future editions of this newsletter.
Transfer Pricing News No. 2: August 2012
General Anti Avoidance Rule (GAAR)
a view to bringing forward legislation in The proposed GAAR does not In December 2010, the UK government the Finance Bill 2013. The government include a provision for a clearance asked a leading barrister (Graham has now released a consultation mechanism. Grant Thornton UK believe Aaronson QC) to lead an independent document which has been welcomed by that the GAAR will not have a major study that would consider whether a most tax advisors.
impact on TP because the TP rules GAAR could deter and counter tax The proposed GAAR is envisaged to already require taxpayers to price their avoidance, whilst retaining a tax regime apply to income tax, corporation tax transactions at arm's length. However it that is attractive to businesses. In his (including transfer pricing (TP)), capital is intended to deter anyone looking to independent report, Graham Aaronson gains tax, petroleum revenue tax, introduce aggressive tax-driven schemes.
concluded that a GAAR would deter inheritance tax and national insurance wholly unacceptable artificial tax contributions but VAT is excluded. avoidance schemes. Fundamental to the proposed Grant Thornton UK The government accepted Graham GAAR is the ‘double reasonableness Aaronson's conclusion and agreed that a test' as the key provision that drives the ‘broad spectrum' anti-abuse rule would application of the GAAR, whereby not be beneficial for the UK tax system.
arrangements are to be considered Subsequently the UK government abusive if they ‘cannot reasonably be announced in its Budget 2012 that it regarded as a reasonable course of would consult on a GAAR targeted at action, having regard to all the artificial and abusive tax avoidance with Transfer Pricing News No. 2: August 2012
Who's whoContributors Toshiya Kimura
2012 Grant Thornton Grant Thornton Belgium
Grant Thornton Japan
International Ltd. All rights Rose Zhou
Michiel van den Berg
This information has been Grant Thornton China
Grant Thornton Netherlands
provided by member firms within Grant Thornton International Ltd, and is for informational purposes only. Neither the respective Grant Thornton Germany
Grant Thornton UK
member firm nor Grant Thornton International Ltd can guarantee the accuracy, timeliness or Karishma Phatarphekar
completeness of the data Grant Thornton India
contained herein. As such, you should not act on the information without first seeking professional tax Grant Thornton International Ltd (Grant Thornton International) and the member firms are not a worldwide partnership.
Services are delivered independently by the Transfer Pricing News No. 2: August 2012
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