Transfer Pricing Resources for Europe
		OECD Country Profiles Austria Belgium Czech Republic Denmark Estonia Finland France Germany Greece Hungary Ireland Italy Luxembourg The Netherlands Norway Portugal Slovak Republic Slovenia Spain Sweden Switzerland United Kingdom Hungary Overview of Hungary's Transfer Pricing Regime ITD Hungary provides an overview of Hungary's transfer pricing regulations and guidelines.  Hungary's tax authorities have told taxpayers to observe the country's transfer pricing regime or risk facing large penalties. Ireland Finance Bill 2010 The 2010 Finance Bill includes tough new measures for the Revenue Commissioners to tackle transfer pricing by US firms operating in Ireland. The legislation is designed to respond to pressure in Europe and ease overseas concerns that Ireland has a soft touch for aggressive tax planning. Finance Bill 2008 The Finance (No.2) Bill includes a provision that would impede the right to claim correlative adjustments to those Irish taxpayers claiming adjustments under the mutual agreement procedure of Irish tax treaties or under the European Union Arbitration Convention.  The new provision would bar a taxpayer from claiming a deduction, when computing profits, of any amount paid or payable under a contract to a connected person as compensation for a transfer pricing adjustment in a foreign jurisdiction. Italy Ruling 2010/137654 The Tax Authority in Italy has issued a ruling to follow up on transfer pricing documentation law decree 78 that was converted into law on July 30, 2010. The ruling is in line with the EU Transfer Pricing Documentation Code of Conduct and the OECD transfer pricing guidelines. Law Decree 78 Law Decree 78 states that multinational companies engaged in cross-border intra-group transactions should prepare contemporaneous documentation in support of their transfer prices. If documentation is completed contemporaneously, taxpayers will avoid penalty payments if the tax authority disagrees with their pricing. Luxembourg Luxembourg Issues Transfer Pricing Rules Luxembourg tax authorities issued Circular LIR 164/2, which clarifies transfer pricing rules for resident taxpayers. Norway Norwegian Tax Authorities Place Emphasis on Transfer Pricing Pulished report from the Norwegian tax authorities describing their focus on transfer pricing for the fiscal year 2009. The report provides a summary of court cases from 2009 relating to transfer pricing issues.  Report available in Norwegian only. Norway's Proposoals on Intercompany Loans Proposals in Norway that would ease the rules governing the provision of loans from Norwegian subsidiaries to foreign parents.  Report available in Norwegian only. Spain Comprehensive Regulations (Spanish only) These regulations include new documentation requirements necessary to verify related-party transactions.  Also provides guidance on documentation-related penalties, advance pricing agreements, and competent authority procedures. The documentation requirements apply to the 2009 fiscal year. Slovak Republic Slovak Republic Income Tax Act Modifications to the Slovak Republic's Income Tax Act indicate taxpayers have to follow the EU master file approach in organizing and maintaining transfer pricing documentation defending the method used in transactions with related parties.   (click logo for professional transfer pricing services from ECS)