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

South Africa

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Ukraine seeks to strengthen TP practices with new APA procedures

The Cabinet Ministers of Ukraine have published an order that introduces new advance pricing agreements (APA) procedures for the Ukraine. The order, released on 25 July, replaces the former APA procedures that had become obsolete because of changes to TP legislation in December 2014. July 31, 2015

Aggressive audits on foreign taxpayers fail to help Indonesia reach tax targets

The Indonesian Directorate General of Taxation (DGT) has fallen behind its target for tax collection this year despite an aggressive audit programme focused on multinational enterprises and their use of TP. July 29, 2015

Australian Tax Office refreshes APA procedures

The Australian Tax Office (ATO) has released the formalised details of updates to APA procedures and practices. July 28, 2015

Number of APAs set to increase with BEPS guidance

With the onset of BEPS final guidance in October, companies’ tax teams are recognising a need to review their historic business structures and, in many cases, apply for advance pricing agreements (APA) to safeguard future transactions. July 28, 2015

Companies to hire more staff to cope with BEPS and TP burden

BEPS guidance and legislation signals a turning point in international corporate tax with companies and governments having to make significant changes to manage the compliance burden. July 27, 2015

Brazil implements disclosure mechanism in the context of BEPS Action Plan 12

Following the trends of countries such as Spain and Mexico, among others, Brazil has begun to amend and introduce new legislation to reflect BEPS recommendations in its internal legislation. July 27, 2015

Brazilian Federal Revenue Secretariat clarifies application of PCI and PECEX methods

Consultation Solution no. 176, published by the Brazilian Federal Revenue Secretariat on July 8, 2015, made clear the tax administration’s position to require application of the PCI and Pecex methods on import and export transactions involving commodities, by determining the reliable sources of information to obtain the parameter prices for the transfer pricing calculation. July 27, 2015

How the digital economy will impact your specific industry

The digital economy is an increasing concern for taxpayers, especially in light of impending BEPS guidance, but how it will impact different industries will vary. July 22, 2015

India plans to resolve investment fund tax issues but will likely disappoint

The Indian government is planning to clarify tax guidance for investment funds in India but there is little confidence it will satisfy offshore funds’ needs. July 21, 2015

UN’s G77 call for end to OECD’s dominance in international tax policy

The UN’s Third Financing for Development Conference took place in Addis Ababa last week. Tax was central to the conversation as the G77 (made up of 134 developing countries) and some aid agencies proposed a-UN headed international tax agency to replace the OECD-dominated system. July 21, 2015

Schlumberger Australia to settle Australian Tax Office TP claim

Schlumberger Australia, contractor to oil companies BHP and Chevron, agreed to pay the Australian Tax Office (ATO) AUS$51.9 million ($38.3 million) to settle a two year TP review. July 21, 2015

European parliament votes for public country-by-country reporting

MEPs last week approved draft rules that would require companies to publically disclose country-by-country reports. The decision is part of a wider document that, if put into legislation, would also give shareholders a say on directors’ pay. July 13, 2015

The new look JTPF: Why transfer pricing is not just for the technicians

On 26 January this year the EU Joint Transfer Pricing Forum (JTPF) had its mandate extended for the third time. This time there was a twist: for the first time representatives were invited to the forum from civil society. July 13, 2015

Majority of taxpayers are concerned IT systems are not up to scratch for BEPS

The majority of taxpayers, in a survey by TPWeek, have said they think the IT systems available on the market for corporate tax and transfer pricing are insufficient in helping companies to cooperate with documentation and the country-by-country reporting obligations of the upcoming BEPS guidance. July 01, 2015

Germany moves towards country-by-country legislation

The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country-by-country (CbC) reporting) of the OECD’s BEPS project into local legislation. July 01, 2015

Pfizer, Novartis and AstraZeneca among companies called to Australian senate inquiry

Nine multinational drug companies have come under scrutiny from the Australian authorities. The companies were called before a senate committee hearing today after data showed that, from their combined revenue of AUS$8.2 billion ($6.3 billion), they had paid AUS$85 million. July 01, 2015

WCO working with ICC to overcome TP and customs discrepancies

The World Customs Organization (WCO) has released a new guide on customs valuation and TP. The guide includes recommendations from the International Chamber of Commerce (ICC) to converge disparate TP and customs policies. June 30, 2015

Read the most popular articles so far this year on TPWeek

An exclusive interview with Andrew Hickman, head of TP at the OECD, along with insights from LEGO China, guides to engage the board in a company’s TP affairs and IP risks in asset management, are the most popular articles so far on TPWeek. June 29, 2015

A quarter of companies’ tax departments will not receive any extra resources to cope with BEPS changes

A TPWeek survey has revealed that country-by-country reporting (CbCR) is the biggest worry for multinationals before the final BEPS outcomes are revealed in October and that an alarming proportion of companies have not spoken to their board about BEPS. Of those who have, a large percentage will not be receiving any extra resources to cope. June 29, 2015

Importance of comparability factors in transfer pricing analyses

The Italian Supreme Court has ruled that transfer pricing adjustments applied by the tax authorities may be deemed legitimate even if they have been applied after a comparison between the transactions assessed and the ones carried out by and among third independent parties. June 29, 2015

Why alleviation of double taxation is not keeping pace with BEPS work

Taxpayers are becoming concerned the OECD’s aim to alleviate double taxation is being out-paced by the BEPS work. Isabel Verlinden, Patrick Boone, Gaby Bes, and David Swenson of PwC explain why this concern is justified. November 26, 2014

Consensus over definition of intangibles and location savings increasingly unlikely

Action 8 of the OECD’s BEPS project on the transfer pricing aspects of intangibles aims to achieve universal consensus over definition. However, this is beginning to look like an impossible task, with influential BRIC countries such as India, making their own interpretations. December 10, 2014

Asia transfer pricing special focus

Transfer pricing in Asia is a rapidly developing market for taxpayers, their advisers and the authorities. TPWeek held its third annual Global Transfer Pricing Forum in Singapore on December 2&3 with a record turn-out from delegates and featuring two keynote speeches from OECD officials. December 17, 2014

China’s APA stats show acceptance of different TP methods

China’s State Administration for Taxation (SAT) released its advance pricing agreement (APA) statistics for 2013 on December 5 2014. January 12, 2015

Taxpayers criticise Chinese regulations

China’s transfer pricing regulations, which were published on January 9, will affect how companies manage their tax affairs and add to their compliance costs, say tax directors February 11, 2020

New transfer pricing partner at PwC Ireland

June 18, 2015

DLA Piper boosts TP practice from London office

June 17, 2015

Andersen Tax boosts TP department in US

June 10, 2015

Transfer pricing attorney joins Baker & McKenzie

Transfer pricing attorney, Barbara Mantegani, has joined Baker & McKenzie’s Washington DC tax practice as counsel. April 08, 2015

Schoeneborn joins EY from Merck

Dr. Frank Schoeneborn joins EY as a partner in EMEIA Tax Centre focusing on intercompany effectiveness and operational transfer pricing. March 27, 2015

Singapore updates its transfer pricing guidelines

The Singapore revised transfer pricing (TP) guidelines, published January 6 2015, require taxpayers to prepare and maintain contemporaneous TP documentation to support TP positions and have this in place by the time the company’s tax return is filed. January 19, 2015

New TP reforms in Ukraine likely to ramp up disputes and prolong audits

The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pricing control. January 14, 2015

China focuses on cross-border transactions in war on tax evasion

The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. The move signals a crackdown on profit shifting, which could see cross-border transactions increasingly scrutinised. January 12, 2015

Lack of transfer pricing rules leads to questionable audits in Hong Kong

Despite a self-touted reputation as a leading global financial centre, Hong Kong’s Inland Revenue Department (IRD) has been criticised by tax practitioners for overly aggressive audits on asset managers. Hong Kong has limited transfer pricing legislation and often seeks to enforce arm’s-length pricing through practice notes and a network of tax treaties. January 08, 2015

The transfer pricing implications of the Italian regional tax on productive activities

The provincial tax court of Reggio Emilia has issued ruling No 510/03/14 relating to the Italian regional tax on productive activities (IRAP). January 06, 2015

Reduction in maximum income tax rate for inclusion in Brazil’s black and grey lists

The Brazilian Ministry of Finance has issued Portaria MF no. 488/2014, on December 1, which reduced the maximum income tax rate from 20% to 17% for the purposes of applying the concepts of tax havens and privileged tax regimes. December 08, 2014

Swedish Tax Agency reviews TP legislation and proposes changes

The Swedish Tax Agency has, on request by the Swedish Government (Ministry of Finance), evaluated the transfer pricing documentation rules’ functionality and proposed possible changes to simplify the application. December 08, 2014

The dangers of creating an accidental PE and how to avoid it

As companies’ employees become more globally mobile, there is an increasing risk that a permanent establishment (PE) may occur unintentionally, leaving taxpayers at risk of taxable income liabilities. November 28, 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

Hong Kong signs first bilateral APA

Hong Kong has agreed its first bilateral advance pricing agreement (APA) since its scheme began in March 2012. EY, who facilitated the deal between Hong Kong and the Netherlands, explain how the process progressed with the authorities. July 10, 2014

Marzen Aluminum ruling based on structuring rather than pricing

The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The ruling is significant because it is the first Canadian decision focusing on the structuring of transactions rather than the pricing. June 26, 2014

Netherlands reclaims Swiss company’s profits and applies penalties in transfer pricing case

The Dutch District Court of Zeeland/West-Brabant ruled, on January 17 2014, on a Swiss Captive Insurance company (without employees), taxing most of its profits back in the hands of a related Dutch taxpayer with 50% penalties. March 18, 2014

Intangible assets in the media and entertainment industries: In depth analysis

The US television production industry reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look at dealing with intangibles. February 18, 2014

The transfer pricing considerations of Suzuki’s 100% subsidiary in India

Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implications, which must be considered by any multinational in this position. February 04, 2014

McKesson Canada: CRA wins in Tax Court but taxpayer files with Court of Appeal

The Canada Revenue Agency (CRA) saw pharmaceutical company McKesson’s arguments dismissed by the Tax Court in December 2013 but the company has now filed its arguments with the Federal Court of Appeal. January 24, 2014

How to organise your TP department to avoid dispute

Governments' hard-line approaches to companies' transfer pricing arrangements has resulted in a rise in transfer pricing cases being resolved in court, explains Fabrizio Lolliri, European director of transfer pricing for Hogan Lovells. January 21, 2014

The new cost of global compliance: Private company data for local comparables

All of us in the tax world know that transfer pricing has been a hot topic this year. Around the globe, tax authorities have become more aggressive, primarily to reduce government fiscal deficits. January 20, 2014

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

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

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

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