International Indirect Tax - Global VAT/GST update (March 2018)Alex Baulf
These are the slides from the International Indirect Tax - Global VAT/GST update presented at Grant Thornton's VAT Club held in London on 9th March 2018.
The topics discussed include:
EU
• Bulgarian Presidency
• VAT Action Plan – proposal for a Definitive VAT System based on destination principle
• Customs: Binding Valuation Information (BVI)
• Considerations for using TP for Customs value
• Hungary: Electronic Invoicing
• Spain: SII 1.1 new version
• Italy: Simplifications to “Communications of data of invoices issued and received”
• Italy: Mandatory e-invoicing?
EMEA
• South Africa: VAT rate increase
• GCC – where are we?
• UAE: What's been released ? What's missing? Designated Zones
NOAM
• USA: Landmark sales tax nexus case to be heard in Supreme Court
APAC
• India: GST update
• China: Further VAT reform
• Malaysia: GST Compliance Assurance Program (MyGCAP)
• Singapore: Future GST rate increase / reverse charge
• Australia: Final guidance published for online retailers - GST on low value imported goods
This publication has been prepared only as a high level guide. No responsibility can be accepted by us for loss occasioned to any person acting or refraining from acting as a result of any material in this publication.
The Spanish Tax Authorities have announced that they start to impose penalties for the non-compliance with the Immediate Supply of Information on VAT (ISI). The ISI entered into force last 1 July 2017, but the appropriate regulation of certain specific penalties did not come into effect until 1 January 2018.
The most important changes that were introduced to the Russian Tax Code, accounting and audit law in 2015 and will come into force on January 01, 2016. recommendations about the latest transfer pricing practices as and taxation of interests for intra-group loans.
Through the Fiscal Bulletin sent on September 4, 2017, we announced the introduction of the VAT split payment mechanism by Government Ordinance No. 23/2017. After the Ordinance passed the Parliament approval through a law and the Approval Law was published in the Official Gazette, the VAT split payment mechanism has undergone major changes – in a positive way for most taxpayers.
With IMC’s comprehensive action plan you can take control of VAT’s impact on people and organizations, processes and controls, and data and technology.
Slides from the Presentations that were hosted by M&J Consultants and the Zimbabwe Revenue Authority focused on Tax Updates for the 4th Quarter of 2020.
International indirect tax - the view from Grant ThorntonAlex Baulf
This placemat sets out two indirect tax issues facing businesses with a global footprint or international supply chain and some of Grant Thornton's solutions:
• How can we manage indirect tax in our global supply chain?
• How can we manage our VAT, GST and sales tax compliance obligations globally?
This also sets out details of what Grant Thornton sees as the current hot topics in indirect tax:
• Automation and tax technology
• Taxing the digital economy
• Focus on processes and controls
International Indirect Tax - Global VAT/GST update (March 2018)Alex Baulf
These are the slides from the International Indirect Tax - Global VAT/GST update presented at Grant Thornton's VAT Club held in London on 9th March 2018.
The topics discussed include:
EU
• Bulgarian Presidency
• VAT Action Plan – proposal for a Definitive VAT System based on destination principle
• Customs: Binding Valuation Information (BVI)
• Considerations for using TP for Customs value
• Hungary: Electronic Invoicing
• Spain: SII 1.1 new version
• Italy: Simplifications to “Communications of data of invoices issued and received”
• Italy: Mandatory e-invoicing?
EMEA
• South Africa: VAT rate increase
• GCC – where are we?
• UAE: What's been released ? What's missing? Designated Zones
NOAM
• USA: Landmark sales tax nexus case to be heard in Supreme Court
APAC
• India: GST update
• China: Further VAT reform
• Malaysia: GST Compliance Assurance Program (MyGCAP)
• Singapore: Future GST rate increase / reverse charge
• Australia: Final guidance published for online retailers - GST on low value imported goods
This publication has been prepared only as a high level guide. No responsibility can be accepted by us for loss occasioned to any person acting or refraining from acting as a result of any material in this publication.
The Spanish Tax Authorities have announced that they start to impose penalties for the non-compliance with the Immediate Supply of Information on VAT (ISI). The ISI entered into force last 1 July 2017, but the appropriate regulation of certain specific penalties did not come into effect until 1 January 2018.
The most important changes that were introduced to the Russian Tax Code, accounting and audit law in 2015 and will come into force on January 01, 2016. recommendations about the latest transfer pricing practices as and taxation of interests for intra-group loans.
Through the Fiscal Bulletin sent on September 4, 2017, we announced the introduction of the VAT split payment mechanism by Government Ordinance No. 23/2017. After the Ordinance passed the Parliament approval through a law and the Approval Law was published in the Official Gazette, the VAT split payment mechanism has undergone major changes – in a positive way for most taxpayers.
With IMC’s comprehensive action plan you can take control of VAT’s impact on people and organizations, processes and controls, and data and technology.
Slides from the Presentations that were hosted by M&J Consultants and the Zimbabwe Revenue Authority focused on Tax Updates for the 4th Quarter of 2020.
International indirect tax - the view from Grant ThorntonAlex Baulf
This placemat sets out two indirect tax issues facing businesses with a global footprint or international supply chain and some of Grant Thornton's solutions:
• How can we manage indirect tax in our global supply chain?
• How can we manage our VAT, GST and sales tax compliance obligations globally?
This also sets out details of what Grant Thornton sees as the current hot topics in indirect tax:
• Automation and tax technology
• Taxing the digital economy
• Focus on processes and controls
International Indirect Tax Update - March 2016Alex Baulf
In this VAT Club "International Indirect Tax Update" presentation, Grant Thornton UK LLP's Alex Baulf, Henry-Cairns-Terry and Ben Price, present an update on VAT, GST and Customs from across the globe. This includes:
1. EU case law and policy update
2. Union Customs Code update
3. New regimes, rates and rules
Slides are from Grant Thornton UK LLP's VAT Club seminar event held in London on 9th March 2016.
Back to Basics: VAT invoicing & the reverse chargeAlex Baulf
In this VAT Club "Back to Basics" presentation, Grant Thornton UK LLP's Hugh Doherty & Arsalan Aslam present on valid VAT invoicing, self-billing and the reverse charge.
What are the new VAT administrative penaltiesAhmedTalaat127
The Federal Tax Authority (FTA) shared a public clarification on 28th April 2021 about the amendments for provisions under the Cabinet Decision No 40 of 2017 for administrative penalties. VAT penalties include administrative penalties, which mean the monetary fines imposed on a person or an entity by the FTA for breaching the provisions in the Tax Law of UAE. Penalties can easily be avoided by taking the necessary precautions for non-compliance while filing the VAT report. Businesses have more time to review their data and submit an accurate VAT filing and can benefit from up to 70% waiver for their unpaid penalties if they meet the criteria.
Cyprus VAT Alert - Obligation for Submission of VAT Returns ElectronicallyAlex Baulf
The Taxation Department has informed that pursuant to the amendment of Regulation 17, of the VAT Regulations (Κ.Δ.Π 367/2016), all taxable persons from 2/5/2017 will have an obligation to submit their VAT return (Form VAT4) electronically. The relevant provisions exempt from this obligation any persons who are subject to the agricultural scheme and the special regime for taxis.
Please see full alert attached.
On 2 December 2016 the Law Decree 22 October 2016 n. 193 (“Tax decree”) completed its legislative process with the publication in the Official Gazette of the consolidated text, post amendments, occurred at the time of the conversion into Law. Some of the adopted measures are a way to implement the new strategy of the Tax Administration to prevent tax evasion and to reduce the VAT gap. Most of the measures have the aim to modernize the way in which taxable persons accomplish VAT fulfillments, so that these latter can be more effective, leveraging on an intense use of electronic means. Grant Thornton Italy summarize in this VAT Alert, the main changes on VAT rules deriving from the final text of the new provisions.
This is the proposed VAT Law in Dubai, the act is yet to come and then i will present one more presentation with the actual law. Kindly note that this is just for the overview and please don't make decisions on the basis of the same.
Presentation to customers at HP Tech@Work in Singapore 2010, discusses the technology and transformational approach to implementing a Converged Infrastructure
One of the most challenging issues in BPM is not the question of "If" it is the question of "How." This two-day program will focus on how to do design and implement efficient and effective business processes, to more effectively support the way our enterprises are adapting.
International Indirect Tax Update - March 2016Alex Baulf
In this VAT Club "International Indirect Tax Update" presentation, Grant Thornton UK LLP's Alex Baulf, Henry-Cairns-Terry and Ben Price, present an update on VAT, GST and Customs from across the globe. This includes:
1. EU case law and policy update
2. Union Customs Code update
3. New regimes, rates and rules
Slides are from Grant Thornton UK LLP's VAT Club seminar event held in London on 9th March 2016.
Back to Basics: VAT invoicing & the reverse chargeAlex Baulf
In this VAT Club "Back to Basics" presentation, Grant Thornton UK LLP's Hugh Doherty & Arsalan Aslam present on valid VAT invoicing, self-billing and the reverse charge.
What are the new VAT administrative penaltiesAhmedTalaat127
The Federal Tax Authority (FTA) shared a public clarification on 28th April 2021 about the amendments for provisions under the Cabinet Decision No 40 of 2017 for administrative penalties. VAT penalties include administrative penalties, which mean the monetary fines imposed on a person or an entity by the FTA for breaching the provisions in the Tax Law of UAE. Penalties can easily be avoided by taking the necessary precautions for non-compliance while filing the VAT report. Businesses have more time to review their data and submit an accurate VAT filing and can benefit from up to 70% waiver for their unpaid penalties if they meet the criteria.
Cyprus VAT Alert - Obligation for Submission of VAT Returns ElectronicallyAlex Baulf
The Taxation Department has informed that pursuant to the amendment of Regulation 17, of the VAT Regulations (Κ.Δ.Π 367/2016), all taxable persons from 2/5/2017 will have an obligation to submit their VAT return (Form VAT4) electronically. The relevant provisions exempt from this obligation any persons who are subject to the agricultural scheme and the special regime for taxis.
Please see full alert attached.
On 2 December 2016 the Law Decree 22 October 2016 n. 193 (“Tax decree”) completed its legislative process with the publication in the Official Gazette of the consolidated text, post amendments, occurred at the time of the conversion into Law. Some of the adopted measures are a way to implement the new strategy of the Tax Administration to prevent tax evasion and to reduce the VAT gap. Most of the measures have the aim to modernize the way in which taxable persons accomplish VAT fulfillments, so that these latter can be more effective, leveraging on an intense use of electronic means. Grant Thornton Italy summarize in this VAT Alert, the main changes on VAT rules deriving from the final text of the new provisions.
This is the proposed VAT Law in Dubai, the act is yet to come and then i will present one more presentation with the actual law. Kindly note that this is just for the overview and please don't make decisions on the basis of the same.
Presentation to customers at HP Tech@Work in Singapore 2010, discusses the technology and transformational approach to implementing a Converged Infrastructure
One of the most challenging issues in BPM is not the question of "If" it is the question of "How." This two-day program will focus on how to do design and implement efficient and effective business processes, to more effectively support the way our enterprises are adapting.
What’s with the Old Guy? A Place for Socrates in the Classroom by Meredith S...NCAIS INNOVATE
During NCAIS Innovate 2010 conference attendees were witness to six, five-minute presentations where presenters showcased one of their passion points about education. We call these sessions SPARKING Education. http://innovate.ncais.org
The presentation provided an overview of the enacted 2017-2018 Pennsylvania State Budget, including a summary discussion of what tax items have been on the table for negotiation during the past few years.
During the second leg of the webinar, the presenter provided a brief update on recently passed tax legislation and court decisions of interest. The Department of Revenue has been active in releasing several important information notices during the first half of 2017 regarding sales tax on computer services as well as appeal process procedural changes. We also took a look at the numbers from the most recent PA Tax Amnesty.
In the final leg of the webinar, we looked ahead at how some of the tax legislation passing in other states may soon be coming to Pennsylvania.
VAT Implementation in KSA (Kingdom of Saudi Arabia)Mitesh Katira
VAT is on the way of implementation in the KSA from 1st of Jan 2018. It is critical for the companies to understand the nuances of the same and work on a roadmap to implement VAT so as to optimize the impact not only on profitability, working capital, pricing but also ERP, team sensitization and vendor education.
VAT is applied in more than 160 countries around the world as a reliable source of revenue for state budgets.
VAT is imposed at each stage of the supply chain from the production and distribution to the final sale of the good or service. The understanding concepts of “Supply”, “Place of Supply” and “Time of Supply” become critically important for effective implementation of KSA VAT.
Here is a simple graphical guide for understanding the KSA VAT.
The GCC member countries have entered into a unified agreement which bind them to implement VAT and Excise regulations in their jurisdictions latest by January 2019. IMC has a dedicated “VAT in GCC” team set-up in Dubai, UAE. Write to us at bc@intuitconsultancy.com or visit https://intuitconsultancy.com/vat-in-middle-east/ for more. IMC would be pleased to advise readers on how to apply the principles set out in this publication to their specific circumstances.
VAT Implementation in Kingdom of Saudi Arabia ( KSA)Mitesh Katira
VAT is on the way of implementation in the KSA from 1st of Jan 2018. It is critical for the companies to understand the nuances of the same and work on a roadmap to implement VAT so as to optimize the impact not only on profitability, working capital, pricing but also ERP, team sensitization and vendor education.
Here is a simple graphical guide for understanding the KSA VAT.
What is Value Added Tax (VAT)?
**An indirect tax imposed at each stage of production and supply.
**In general, the ultimate consumer is the one who bears the full cost of this tax while the business collects and
calculates the tax and pays it in favor of the state.
**A 5% is imposed on multiple production stages with the right to deduct taxes on inputs from taxes collected
from production outputs.
**The tax is collected each stage of the economic cycle (production, distribution, consumption)
Value added = Sale Price – Purchasing or Production cost
VAT is on the way of implementation in UAE from 1st of Jan 2018. It is critical for the companies to understand the nuances of the same and work on a roadmap to implement VAT so as to optimize the impact not only on profitability, working capital, pricing but also ERP, team sensitization and vendor education.
VAT is applied in more than 160 countries around the world as a reliable source of revenue for state budgets.
VAT is imposed at each stage of the supply chain from the production and distribution to the final sale of the good or service. The understanding concepts of “Supply”, “Place of Supply” and “Time of Supply” become critically important for effective implementation of UAE VAT.
Here is a simple graphical guide for understanding the UAE VAT.
VAT is on the way of implementation in the UAE from 1st of Jan 2018. It is critical for the companies to understand the nuances of the same and work on a roadmap to implement VAT so as to optimize the impact not only on profitability, working capital, pricing but also ERP, team sensitization and vendor education.
Here is a simple graphical guide for understanding the UAE VAT.
Designed to benefit financial controllers and directors working in commerce, providing an ideal opportunity to update your knowledge on a wide range of subjects.
Discover a Visionary Tax Regime: Uplift Your Financial Horizon!
🚀 Uncover an innovative taxation concept that's never been featured before and holds the potential to redefine taxation in India.
🌐 Witness the imbalances in the current tax system as a small percentage of the population shoulders the bulk of the burden.
🌟 Imagine introducing a fresh approach that harnesses financial data and the power of digital transactions.
💡 Embrace India's digital transaction surge – a staggering 3021 trillion INR exchanged in 2021-22, signaling a forward-looking nation.
📊 Picture implementing a modest 2% digital transaction tax, resulting in a remarkable 242% surge to 60.42 trillion INR, far surpassing net tax collections.
🔍 Envision a scenario where this digital tax exclusively targets income tax-paying individuals – potential for a transformative 70% to 90% reduction in their tax burden.
📄 Dive into a comprehensive Digital Transaction Tax document, drawing insights from credible sources, and explore diverse tax proposals.
🗣 Your voice matters; share your insights on platforms like the Grievance Portal to amplify the impact of this revolutionary idea.
🎯 Be part of positive change. Your involvement shapes the trajectory of Indian taxation and financial empowerment.
🌈 Wishing you success, inspiration, and an empowered financial future.
Tax Foundation University 2017, Part 6: Tax Reform, the Budget, and the Budge...Tax Foundation
This Tax Foundation University lecture covers:
— How the budget rules affect how you craft a tax reform plan
— How the Blueprint’s designers may have had the budget process in mind
— Alternative revenue sources, spending offsets, other means of coping with budget issues
— Are the deficit effects temporary or permanent?
— Are credits, cost recovery provisions, debt rules retroactive or prospective?
The standard VAT rate will be 5% unless a zero rate or exemption applies.
The Member States have the right to subject the following sectors to a zero rate or to exempt them from VAT:
Education
Health
Real estate
Local transport
The Member States have the right to subject the oil sector, petroleum derivatives, and gas to a zero rate of VAT.
Individual GCC countries have the right to subject certain food products to a zero rate of VAT.
The Member States have the right to subject medical supplies to a zero rate of VAT.
Intra-GCC and international transport will be subject to a zero rate of VAT.
The export of goods to jurisdictions outside of the GCC Member States will be subject to a zero rate of VAT.
The Member States have the right to exempt Financial Services from VAT. The term financial services is not defined but broadly the exemption will generally relate to dealings in money, securities, foreign exchange and the operation and management of loan accounts, deposits, trade credit facilities and related intermediary services. The exemption is not expected to extend to fee based services transacted by a financial institution. However, Member States may choose to apply different VAT treatments to financial services if they wish.
Supplies of goods and services from a VAT registered person in one Member State to a VAT registered person in another Member State are subject to the reverse charge mechanism.
VAT grouping appears to be permitted between two or more legal persons resident in the same Member State.
The treatment of GCC free zones is not addressed and it is left to each Member State to determine its own VAT treatment for free zones.
Businesses with an annual revenue of over AED 375,000 will be required to register for VAT purposes.
Businesses with an annual revenue between AED 187,500 and AED 375,000 will have the option to register for VAT purposes.
Обзор заработных плат в сфере фармацевтического производства в Москве.Awara Direct Search
Цель этого обзора заработных плат – дать общее представление об особенностях рынка труда и уровне средних заработных плат в сфере фармацевтического производства в Москве.
Цель этого обзора зарплат – дать представление об особенностях рынка труда и уровне средних заработных плат в Санкт-Петербурге в период санкций и девальвации рубля.
Исследование Совокупного Налогового Бремени на Оплату Труда – 2014Awara Direct Search
Что мы хотели узнать? Какую часть из всех денежных средств, которые направлены на выплату заработной платы, работники в действительности получают на руки за вычетом налогов и всех отчислений на социальное страхование? Конкретный вопрос, который мы ставили перед собой: Каковыми должны быть совокупные расходы работодателя на оплату труда, чтобы работник получил на руки X евро (долларов США)?
Обзор заработных плат в области подбора персонала в КазаниAwara Direct Search
Цель этого обзора заработных плат – дать общее представление об особенностях рынка труда и уровне средних заработных плат в сфере строительства в Казани.
Обзор заработных плат в области подбора персонала в Санкт-ПетербургеAwara Direct Search
Цель этого обзора заработных плат – дать общее представление об особенностях рынка труда и уровне средних заработных плат в области HR в Санкт-Петербурге
Yes of course, you can easily start mining pi network coin today and sell to legit pi vendors in the United States.
Here the what'sapp contact of my personal vendor.
+12349014282
#pi network #pi coins #legit #passive income
#US
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the what'sapp contact of my personal pi merchant to trade with.
+12349014282
Lecture slide titled Fraud Risk Mitigation, Webinar Lecture Delivered at the Society for West African Internal Audit Practitioners (SWAIAP) on Wednesday, November 8, 2023.
how to sell pi coins in South Korea profitably.DOT TECH
Yes. You can sell your pi network coins in South Korea or any other country, by finding a verified pi merchant
What is a verified pi merchant?
Since pi network is not launched yet on any exchange, the only way you can sell pi coins is by selling to a verified pi merchant, and this is because pi network is not launched yet on any exchange and no pre-sale or ico offerings Is done on pi.
Since there is no pre-sale, the only way exchanges can get pi is by buying from miners. So a pi merchant facilitates these transactions by acting as a bridge for both transactions.
How can i find a pi vendor/merchant?
Well for those who haven't traded with a pi merchant or who don't already have one. I will leave the what'sapp number of my personal pi merchant who i trade pi with.
Message: +12349014282 VIA Whatsapp.
#pi #sell #nigeria #pinetwork #picoins #sellpi #Nigerian #tradepi #pinetworkcoins #sellmypi
5 Tips for Creating Standard Financial ReportsEasyReports
Well-crafted financial reports serve as vital tools for decision-making and transparency within an organization. By following the undermentioned tips, you can create standardized financial reports that effectively communicate your company's financial health and performance to stakeholders.
Financial Assets: Debit vs Equity Securities.pptxWrito-Finance
financial assets represent claim for future benefit or cash. Financial assets are formed by establishing contracts between participants. These financial assets are used for collection of huge amounts of money for business purposes.
Two major Types: Debt Securities and Equity Securities.
Debt Securities are Also known as fixed-income securities or instruments. The type of assets is formed by establishing contracts between investor and issuer of the asset.
• The first type of Debit securities is BONDS. Bonds are issued by corporations and government (both local and national government).
• The second important type of Debit security is NOTES. Apart from similarities associated with notes and bonds, notes have shorter term maturity.
• The 3rd important type of Debit security is TRESURY BILLS. These securities have short-term ranging from three months, six months, and one year. Issuer of such securities are governments.
• Above discussed debit securities are mostly issued by governments and corporations. CERTIFICATE OF DEPOSITS CDs are issued by Banks and Financial Institutions. Risk factor associated with CDs gets reduced when issued by reputable institutions or Banks.
Following are the risk attached with debt securities: Credit risk, interest rate risk and currency risk
There are no fixed maturity dates in such securities, and asset’s value is determined by company’s performance. There are two major types of equity securities: common stock and preferred stock.
Common Stock: These are simple equity securities and bear no complexities which the preferred stock bears. Holders of such securities or instrument have the voting rights when it comes to select the company’s board of director or the business decisions to be made.
Preferred Stock: Preferred stocks are sometime referred to as hybrid securities, because it contains elements of both debit security and equity security. Preferred stock confers ownership rights to security holder that is why it is equity instrument
<a href="https://www.writofinance.com/equity-securities-features-types-risk/" >Equity securities </a> as a whole is used for capital funding for companies. Companies have multiple expenses to cover. Potential growth of company is required in competitive market. So, these securities are used for capital generation, and then uses it for company’s growth.
Concluding remarks
Both are employed in business. Businesses are often established through debit securities, then what is the need for equity securities. Companies have to cover multiple expenses and expansion of business. They can also use equity instruments for repayment of debits. So, there are multiple uses for securities. As an investor, you need tools for analysis. Investment decisions are made by carefully analyzing the market. For better analysis of the stock market, investors often employ financial analysis of companies.
BONKMILLON Unleashes Its Bonkers Potential on Solana.pdfcoingabbar
Introducing BONKMILLON - The Most Bonkers Meme Coin Yet
Let's be real for a second – the world of meme coins can feel like a bit of a circus at times. Every other day, there's a new token promising to take you "to the moon" or offering some groundbreaking utility that'll change the game forever. But how many of them actually deliver on that hype?
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
2. • Tax authorities rely on TP Rules to fight capital
outflow
• 4,600 notifications in 2012. Much or too little?
• Head of Tax Service: approx. 300 reported
transactions raised suspicion
• Filling in gaps in TP regulations?
TP First results
3. • All related-party cross-border transactions are
now subject to transfer pricing rules. NO
EXCEPTIONS.
• More administrative burden: documentation
and reporting obligations.
• Transfer pricing audits. Deadline for initiating
audits for 2012 is June 30, 2014. First audits
are expected shortly
More control
4. Reporting
• To be filed by May 20 of the year following the
reporting year
• Requires a lot of efforts to collect the required
information. The content of TP report is under
Supreme Commercial Court consideration with
a view to decrease the volume of information
to be reported
5. Reporting. Content
AS PER TAX CODE ADDITIONAL TAX SERVICE
REQUIREMENTS
• Year of transactions
• Subject of transactions
• Basic information about the parties to
transactions
• Revenue derived from or losses incurred
under such transactions
• Grounds for qualifying transactions
controlled transactions
• Delivery terms and measurement units
• Country of origin of goods
• Place of transaction and shipment of goods
• Product unit price and quantity
• Additional information about the parties to
transactions
• Transfer pricing methods (Optional)
• Information sources used for benchmarking
(Optional)
6. Price control
• Controlled transactions? Of course!
• If a transaction is not subject to TP rules
(uncontrolled), is there any price control?
Ministry of Finance: Yes, under general tax
anti-avoidance rule.
7. Intragroup financing
• NOW: 3 sets of regulations
• Transfer pricing rules plus
• Thin capitalization rule plus
• General deductibility rate rule
• PLANNED: Thin capitalization rule plus
transfer pricing if interest rates are above set safe
harbors only
• FROM 2015: Thin capitalization rule plus
transfer pricing (TP safe harbors are set for
financing transactions with banks)
8. Intragroup financing
• Are interest free loans now
allowed? Not really, but they are no
longer absolutely prohibited.
• TP reporting and documentation
requirements are waived for loans,
credits, sureties, bank guarantees
concluded before 2012, unless
revised after 2012
9. How can companies protect
themselves?
If tax authorities contest
the price and charge
additional taxes
• Late payment interest (1/300
of refinancing rate (8.25%))
• Penalty 20% of unpaid taxes
in 2014-2017
• Penalty 40% of unpaid taxes
from 2017 onwards
What can be done?
• Transfer pricing self-
adjustment + payment
additional tax prior to TP
audit
• Provide tax authorities with
transfer pricing
documentation
10. Thank you
Anton Kabakov
Partner at Hellevig, Klein & Usov Llc
anton.kabakov@awaragroup.com
+7 921 39 711 93
The content of this presentation cannot substitute legal counseling, which, to be
duly rendered, always requires actual and specific knowledge of the client’s
particular situation.
