The OECD will review and revise its transfer pricing guidance on intangibles later this year in an effort to clarify one of the most frustrating and notoriously inconsistent areas of international tax.
June 10, 2010
Tax directors from multinational companies expressed alarm over shifts in transfer pricing trends during a panel at the joint American Bar Association and International Fiscal Association event in Copenhagen.
June 09, 2010
A mutual agreement between the Netherlands and the US which amends the procedure of obtaining an exemption from dividend withholding tax under the Netherlands-US tax treaty makes sense as it affords the US government responsibility for deciding if US entities qualify for relief under the treaty.
June 09, 2010
New transfer pricing rules failed to be passed into law within the Constitutional deadline, creating controversy as to which rule applies to transactions carried out since the beginning of the year.
June 07, 2010
A mutual agreement has been settled between the competent authorities of the Netherlands and the US which amends the procedure by which US pension funds obtain an exemption from dividend withholding tax under the Netherlands-US tax treaty.
June 02, 2010
Waman Kale and Vinita Chakrabarti report on a judgment by the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) relating to the information technology, business process outsourcing sector.
May 27, 2010
K R Girish and Rohan Phatarphekar of KPMG discuss the reported agreement reached by the Indian and US competent authorities.
May 26, 2010
Yvonne Cypher joined the firm in 1997 and specialises in transfer pricing with a particular focus on business restructuring.
July 28, 2010
Steven Tseng, China partner in charge and Asia Pacific leader for KPMG’s global transfer pricing services is moving to PricewaterhouseCoopers in China, at the same time as many new appointments are made in the US.
July 16, 2010
The acquisition by LECG, a global business advisory and professional services firm, of Bourne Business Consulting, a London firm, closed on July 2.
July 13, 2010
David Borkovec has been made a partner in the PricewaterhouseCoopers tax and legal services department in Prague.
July 13, 2010
Holly McClellan, a partner of Baker & McKenzie in Chicago, will join the corporate tax group at General Electric as transfer pricing leader, tax counsel, for treasury and capital markets on August 16.
July 09, 2010
Robert Kirschenbaum has moved from Baker & McKenzie to join Miller & Chevalier Chartered in Washington, DC.
July 01, 2010
After 21 years with Ernst & Young, Mike Patton is leaving the firm to join DLA Piper.
June 30, 2010
Canadian law firm Blake Cassels & Graydon has taken two tax litigators from rival McCarthy Tétrault.
June 29, 2010
Pendo Advisors, a corporate finance and valuation advisory firm in Chicago, has announced the addition of Dan Bourgeois, who has a tax and transfer pricing background, as a managing director
June 29, 2010
Fred O’Riordan, formerly with the CRA, talks about moving into the private sector and reveals his hopes for the future of arbitration between the US and Canada.
June 23, 2010
Elen Orsini has left the Brazilian Federal Revenue Service and joined Machado Associados.
June 15, 2010
Akin Gump Strauss Hauer & Feld is opening a new office in Geneva, Switzerland. New partner Jonathan Ivinson has significant transfer pricing experience.
June 11, 2010
As part of a firm-wide restructuring, Vaish Associates has promoted two transfer pricing associates to salaried partner level.
June 11, 2010
Brian Trauman has joined KPMG's economic and valuation services practice as a principal and the new East region leader of the transfer pricing controversy services practice. He will be based in New York.
May 26, 2010
Decree number 392/009 amends and clarifies some of the detailed regulations established by decree number 56/009, which was issued in January 2009.
October 05, 2009
Alexander Voegele and Hendrik Fuegemann of NERA Economic Consulting outline how new administrative guidelines are affecting taxpayers’ application of the relocation of functions regulations in Germany
October 01, 2009
A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of goods purchased by Brazilian legal entities and packed or repacked locally for resale.
October 01, 2009
Loss-making documentation is a catch-22 situation in China. Glenn DeSouza, managing director at Transfer Pricing Management Consulting in Shanghai, which has an exclusive strategic alliance with Baker & McKenzie, explains the difficulties
September 17, 2009
India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules
September 08, 2009
The introduction of new transfer pricing documentation rules has led to taxpayers facing more frequent and detailed audits of their activities than ever before.
August 12, 2009
The US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties
September 08, 2009
What does the introduction of advance pricing arrangements mean for taxpayers in India?
September 01, 2009
In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing.
September 01, 2009
In a series of amicus briefs filed with the US Court of Appeals for the Ninth Circuit, several powerful groups have expressed their support for Xilinx in the latest phase of its battle with the Internal Revenue Service.
August 25, 2009
An important concession helpful to manufacturers using mainland China contract processors has been denied.
August 19, 2009
What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn?
August 17, 2009
Marko Saag of Glimstedt Straus & Partners Law Firm explains the transfer pricing documentation obligations in Estonia.
March 09, 2010
Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime.
March 08, 2010
Dirk Van Stappen of the KPMG in Belgium, provides a definitive guide to transfer pricing documentation policy.
March 01, 2010
Ken Okawara, Yukiko Komori, Satoko Kawamura, and Koji Oshima of Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) review the Japanese documentation situation.
March 01, 2010
Mirko Rapa and Berta Pisani Bencini of PricewaterhouseCoopers in Malta describe the country's documentation requirements
March 01, 2010
Ionut Simion and Blanca Kovari, of PwC in Bucharest, explain the Romanian tax authorities’ attitude towards transfer pricing documentation.
March 01, 2010
Denes Szabo, tax partner and Hedvig Solyomvari, senior manager at Ernst &Young Budapest outline the transfer pricing documentation framework in Hungary.
February 25, 2010
Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine
February 25, 2010
Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore.
February 22, 2010
Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers
February 11, 2009
Steven Tseng and Chi Cheng, KPMG China
January 21, 2009
Ramazan BİÇER, senior transfer pricing specialist in the Transfer Prising Division of the Turkish Revenue Administration, describes the regime for transfer pricing documentation in Turkey
September 04, 2008
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador
August 21, 2008
Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine
June 23, 2008
Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year
April 24, 2008
Mirko Rapa, of PricewaterhouseCoopers in Valetta, describes the regime for transfer pricing documentation in Malta
April 15, 2008
Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing
June 03, 2008
Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping
June 05, 2008
Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil
June 04, 2008
In the second in our series on double tax treaties, Gustavo López-Ameri of Deloitte & Touche in Lima reports on Peru's transfer pricing policy
May 30, 2008
KR Girish and Rohit Jain, of TP Week correspondent KPMG in India look at the impact of double tax treaties and transfer pricing
May 28, 2008
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
Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta
April 15, 2008
Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process
April 07, 2008
Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit
April 06, 2008
Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland
March 14, 2008