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Which member of the BRICS has the most developed TP regime?

Brazil
1%
Russia
15%
India
17%
China
15%
South Africa
52%


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Content

Why Indonesia’s PER-22 is more of a hindrance than a useful TP tool

PER-22 was intended to be a tool to help auditors in transfer pricing audits but has in fact led to an overcomplicated and burdensome process. September 18, 2014

GE’s Will Morris on BEPS release: Business still concerned about burdensome reporting requirements

Will Morris, chairman of the BIAC Tax and Fiscal Affairs Committee and global tax policy adviser for GE, weighs up the strengths and weaknesses of the OECD’s BEPS disclosure documents. September 18, 2014


GE’s Will Morris analyses the impact of the OECD’s recent BEPS disclosure documents

Will Morris, chairman of the BIAC Tax and Fiscal Affairs Committee and global tax policy adviser for GE, has spoken exclusively to TPWeek about his views regarding the BEPS disclosure documents released on September 16. September 18, 2014

BEPS: Still no certainty for taxpayers

Despite the base erosion and profit shifting (BEPS) disclosure documents being released today by the OECD there is still scepticism on behalf of industry. September 16, 2014


BEPS quotes: Who said what and when

TPWeek provides an infographic illustrating the BEPS debate in the US and highlighting which key players have said what so far. September 15, 2014

Singapore’s consultation paper on TP documentation proposes master file approach but overlooks CbCR

On September 1 2014, the IRAS issued a consultation paper relating to its transfer pricing (TP) documentation rules. The IRAS issued initial TP guidelines in 2006 and has released a number of e-Tax Guides since then. However, when finalised, the proposed guidelines will require a change in the way taxpayers consider TP compliance in Singapore. September 12, 2014


China’s Circular 146 challenges OECD’s cross-border guidelines with broader TP analysis

The issuing of Circular 146 by the State Administration of Taxation (SAT) highlights the Chinese tax authorities’ increasing efforts to enforce transfer pricing (TP) administration for cross-border charges. Taxpayers with significant amounts of cross-border charges should conduct internal audits to avoid getting caught out. September 11, 2014

How to pick the right IP incentive scheme in Europe

The popularity of intellectual property (IP) incentive schemes is rising steadily, with countries such as the UK, the Netherlands and Switzerland, competing to attract investment. Companies looking to take advantage of these schemes, however, have a number of things to consider. September 09, 2014


Germany: Transfer pricing aspects of business restructurings

By Xaver Ditz and Sven-Eric Bärsch, of Flick Gocke Schaumburg, Bonn, Germany September 03, 2014

Changes to Polish thin cap rules are a headache for taxpayers

The Polish government is making changes to the thin capitalisation rules. It is planned the new legislation will come into force as of January 1 2015 and is being considered by Parliament, though it is expected the changes will happen. September 02, 2014


Determining the transfer pricing policy for liquefied natural gas

Tamir Druz, a director at Capra Energy Group, discusses the best methods for determining an optimal transfer pricing policy for liquefied natural gas (LNG). September 01, 2014

New UK measures to counter avoidance schemes in line with OECD’s BEPS initiative

HM Revenue & Customs (HMRC) has announced new measures to dissuade taxpayers from using avoidance schemes which involve the transfer of corporate profits. Taxpayers will need to familiarise themselves with the new measures and review their company’s arrangements to ensure they are not caught out. August 28, 2014


Motorola shows a way forward in capital asset pricing model

A recent case involving Motorola Solutions India has shown taxpayers a way forward in the use of the capital asset risk pricing model for carrying out risk adjustment. August 28, 2014

Why Russia’s stance on TP guidelines could result in double taxation

In a recent conference, acting head of transfer pricing for the Russian Federal Tax Service, Vladimir Golishevsky, discussed when it is suitable for taxpayers to rely on OECD guidelines. Golishevsky’s statement demonstrates that, while OECD guidelines are becoming widely used, many countries - including Russia - still consider domestic policies to be more suitable in some cases. August 26, 2014


Leading Canadian transfer pricing cases favour domestic rules over OECD guidelines

Until the decision in the GlaxoSmithKline (Glaxo) case, all previous Canadian court decisions had slavishly applied the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. How do the guidelines now fit into the law and a practical strategy of establishing the correct transfer prices? August 21, 2014

Profit splits and value chain analysis key to addressing transfer pricing issues in the digital economy

Paul Morton, head of group tax for Reed Elsevier, writes about the transfer pricing methodologies required for a rapidly developing digital economy. August 18, 2014



What the US bilateral safe harbour should look like

The Internal Revenue Service (IRS) is inviting public comment on the development of bilateral safe harbours with US treaty partners, giving taxpayers and foreign competent authorities the opportunity to influence a safe harbour programme applicable to a large number of cross border transactions. But taxpayers and advisers have said there could still be disadvantages for multinationals. March 27, 2013

IRS stats signal growing faith in APMA programme

The IRS has released statistics on transfer pricing cases for the calendar year 2012 – the first since the formation of the joint advance pricing and mutual agreement (APMA) programme. The figures signal growing taxpayer confidence in the restructured programme. March 26, 2013

How to calculate the UK patent box

HM Revenue & Customs released its guidance on the new patent box regime in its Corporate Intangibles R&D Manuals (CIRD) and a series of road-shows. March 04, 2013

SKAT stats show Denmark’s persistence in assessing IP transactions

The Danish tax authority, SKAT, has published its transfer pricing statistics, which show an increase in revenue from transfer pricing assessments, particularly through intellectual property (IP) transactions. February 07, 2013


New global head of tax and TP at Rosen Group

April 03, 2014

Joe Andrus's replacement as head of transfer pricing at OECD named

Joe Andrus, head of the transfer pricing division of the OECD, announced he would be leaving his post last year. His replacement has now been named. April 03, 2014

New partner at BMR & Associates

April 17, 2014

AlixPartners expands transfer pricing practice

May 14, 2014

KPMG expands TPDR practice

May 29, 2014

Ryan acquires Altus International

June 04, 2014


Indian guidance on R&D centres fails to reduce taxpayer confusion

The Indian Central Board of Direct Taxes (CBDT) has issued guidelines to clarify the transfer pricing treatment of contract R&D centres. However advisers say the advice given is too vague and unlikely to reduce R&D disputes in India. April 04, 2013

Canada broadens thin capitalisation rules in 2013 budget

Canada’s 2013 budget included significant changes to cross-border taxation, including the broadening of the country’s thin capitalisation rules. March 26, 2013

Russian transfer pricing deadline may be delayed because of burdensome notification

The first deadline for taxpayers in Russia to submit details of related-party transactions for 2012 may be delayed until the end of the year because of taxpayers’ concerns over the complexity of the notification requirements. March 19, 2013

Germany proposes to limit participation exemptions for hybrid instruments

The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. The measure may force taxpayers to reassess the pricing of hybrid instruments. March 07, 2013

Korea clarifies arm’s-length calculation of intercompany guarantee transactions

The Korean government has issued guidance on the calculation of the arm’s-length price of guarantee fees for intercompany-guarantee transactions in response to a growing number of disputes involving companies receiving guarantee fees from their foreign subsidiaries. March 05, 2013

Indian safe harbour rules will be issued says Chidambaram

P Chidambaram, the Indian Finance Minister, said in his budget speech today that rules on safe harbours will be issued. February 28, 2013

South Africa limits interest deductibility on related party debt

New limits will be placed on the deductibility of interest on related party debt under the South African budget 2013, announced yesterday. However taxpayers are yet to receive clarification on the application of the arms-length test for inbound financial assistance. February 28, 2013

Taxpayers need cost-sharing law in Russia to combat shared service disputes

Taxpayers need cost-sharing provisions to be written into Russian tax legislation to combat an increased risk of dispute over the allocation of shared service costs. February 19, 2013

OECD unveils G20 report on base erosion and profit shifting

The OECD has identified transfer pricing as one of the challenges for policy makers and taxpayers as they attempt to reform how international tax rules work. February 14, 2013

Why intangible policy discussions are giving Caterpillar’s head of tax “night terrors”

Robin Beran, chief tax officer and director for global tax and trade at Caterpillar, the machinery manufacturer, told delegates at the Tax Council Policy Institute conference on intangibles in Washington today that policy discussions about how to tax intangible assets are giving him “night terrors”. February 13, 2013


Arm's-length value of royalties: Italian case law

Piergiorgio Valente, managing partner of Valente Associati GEB Partners, looks at the Italian case law surrounding the arm’s-length value of royalties. March 20, 2013

Japan-China supply chain efficiency valuation and transfer pricing

Effective tax rate (ETR) planning is critical for all multinational enterprises. From a business flow standpoint, supply chain efficiency is critical. October 30, 2012

IP Structuring: Tax planning ideas for intangible assets

Intangible assets are crucial sources of value and are of increasing strategic importance to companies. October 16, 2012

Polish court challenges procurement transaction

Poland’s Supreme Court recently questioned the economic rationale behind the acquisition of procurement services from a related entity. Aneta Blazejewska–Gaczynska of Ernst & Young explains why this decision should force multinationals to examine their supply chain structures. September 13, 2012

Selecting the interest rate for working capital adjustments

Differences between the tested transaction and the comparable transaction, when applying the transactional net margin method, should be adjusted where such differences materially affect the net profit margin, in accordance with rule 10B(e)(iii) of the Income Tax Rules. September 07, 2012

Where transfer pricing is critical in US oil and gas joint ventures

Complex transfer pricing challenges are arising from the increasing number of joint ventures, particularly in the US, between multinational oil and shale gas exploration companies. July 19, 2012

Siemens’ tips on location saving in Chinese contract R&D arrangements

Location saving is a hot issue. Yin Chao, who specialises in transfer pricing at Siemens in China, and Yin Shuping, who is an associate professor at Guangdong Polytechnique Normal University, explain the transfer pricing aspects of location saving on contract R&D from China’s perspective. July 12, 2012

What the Indian Authority on Advance Rulings thinks of cost contribution arrangements

A case concerning cost contribution agreements in a foreign company provides insight into how they should be structured for Indian taxation purposes. June 01, 2012


Ireland transfer pricing documentation guide

By Barbara Dooley and Gavan Ryle of PwC, Dublin. June 23, 2011

UN tax committee publishes draft transfer pricing manual

The UN Committee of Experts on International Cooperation in Tax Matters will consider its draft Transfer Pricing Manual for Developing Countries at its eighth session in Geneva from October 15-19. October 03, 2012

Ecuador transfer pricing documentation guide

Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador March 23, 2011

Norway transfer pricing documentation guide

Hans-Martin Jørgensen and Michael Vorndran of Deloitte August 09, 2012

Austria transfer pricing documentation guide

By Andrea Lahodny and Gabriele Holzinger of Deloitte August 08, 2012

Canada transfer pricing documentation guide

Todd Miller and Michael Friedman of McMillan in Toronto, Canada explain the documentation rules in Canada and how recent treaty developments and court decision will affect taxpayers. April 20, 2010

Greece transfer pricing documentation guide

By Stefanos Mitsios of Ernst & Young August 08, 2012

Indonesian transfer pricing documentation guide

By Permana Adi Saputra of PB Taxand August 08, 2012

Malaysia transfer pricing documentation guide

By Bernice Tan of Taxand Malaysia August 08, 2012

Denmark transfer pricing documentation guide

Tim Holmes and Thomas Bjerre of Ernst & Young Copenhagen outline the approach to the transfer pricing documentation requirements in Denmark. August 03, 2012

Egypt – Transfer Pricing Documentation Requirements

Anthony Mahon and Andy El Zayaty of Deloitte provide a guide to the transfer pricing requirements in Egypt. December 15, 2010

US transfer pricing documentation guide

By Kathrine Kimball and Minjung Kim of Charles River Associates July 26, 2012

UK transfer pricing documentation guide

By Graham Head (Senior Manager) and Liz Hughes (Transfer Pricing Director), Grant Thornton UK July 24, 2012

South Korea transfer pricing documentation guide

By Taehyung Kim of Deloitte July 23, 2012


HMRC is exchanging unilateral APA information with treaty partners

HMRC is exchanging the terms of its unilateral advance pricing agreements (APA) with UK tax treaty partners. The measure is part of the revenue’s drive towards greater transparency and began this month. February 26, 2013


How to survive a transfer pricing audit in India

Hardev Singh and Saurabh Dhanuka, of KPMG, TP Week’s correspondent in India, give practical advice on dealing with India’s revenue authorities May 22, 2008

How to survive a transfer pricing audit in Malta

Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta April 15, 2008

How to survive a transfer pricing audit in the Czech Republic

Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process April 07, 2008

How to survive a transfer pricing audit in China

Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit April 06, 2008

How to survive a transfer pricing audit in Poland

Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008