Tax alert


Ministry of Finance has prepared a draft amendment in the scope of transfer pricing regulation.

The project is currently in consultations from February 5th 2013.

The main changes will affect:

  • Elimination of hierarchies in terms of selection of the transfer pricing method
  • Simplification of tax audits in scope of law value intangible services
  • Harmonization of procedures regarding benchmark study
  • Introduction of new definition of shareholders costs
  • Introduction of regulation regarding transfer pricing aspects of business restructurings
  •  Amendment prescription in the scope of elimination of
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