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Poll

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

Brazil
1%
Russia
20%
India
21%
China
20%
South Africa
39%


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Content

AstraZeneca and Ecopetrol on managing TP in the board room

Ian Brimicombe, VP of corporate finance at AstraZeneca (based in the UK), and David García Morales, international tax lawyer at Ecopetrol (based in Colombia), share their views on the increasing relevance of transfer pricing at all levels of business. April 20, 2015

Why companies are at risk if their board is not involved in TP

If your company’s board-level executives are not concerned about your transfer pricing operations your company could be at risk during audit. TPWeek speaks to in-house tax directors and their advisers to find out how transfer pricing became a board-level issue and what their companies are doing now. April 16, 2015


BHP Billiton and Rio Tinto come under fire over alleged profit shifting through marketing hubs

Allegations that BHP Billiton and Rio Tinto shifted billions of dollars in iron ore profits through marketing hubs in Singapore has added fuel to the raging debate in Australia over tax avoidance involving multinationals. April 14, 2015

US APA 2014 statistics show loss of productivity

Advance pricing agreements (APAs) statistics for 2014 in the US indicate the Internal Revenue Service’s (IRS) productivity has decreased by 30% from 2013. April 13, 2015


France clarifies abusive tax structures for multinationals

The French tax administration has released a list of 17 structures or schemes it considers to be abusive and has described each structure and outlined the potential liability of re-assessment. April 10, 2015

Italian tax authorities accuse gaming website of €300 million tax evasion

Online gaming site, PokerStars, has been accused of tax evasion totalling €300 million ($326 million) by the Italian tax authorities. April 09, 2015


Seychelles takes steps to clean up its act and rid itself of tax haven status

The Seychelles Revenue Commission (SRC) issued Public Ruling 2015-3 on the application of the arm’s-length principle in transfer pricing. The Seychelles is frequently referred to as a tax haven so any steps to clarify transfer pricing guidelines is welcome by those battling profit shifting. April 09, 2015

How the UN is working for developing countries in BEPS

The UN’s role in transfer pricing policy seems to have quietened since the release of its practical manual on transfer pricing for developing countries in 2013. Particularly now the OECD is dominating the headlines with its BEPS project. April 07, 2015


India’s I-T Department extends roll-back application deadline for TP agreements

India’s Income-Tax (I-T) Department announced the deadline for filing roll-back applications for transfer pricing agreements will be extended. This is welcome news for tax professionals who criticised the government’s aggressive timeline for advance pricing agreements (APAs). April 02, 2015

Why Taiwan’s transfer pricing proposals are too vague for taxpayers

Taiwan’s Ministry of Finance (MOF) has announced proposals to amend transfer prising assessment rules. The proposals suggest greater alignment with the OECD but the announcement has left many important questions unanswered. March 31, 2015


UK diverted profits tax a growing concern for taxpayers

HM Revenue and Customs (HMRC) has responded to criticism from tax professionals over the diverted profits tax (DPT) by narrowing notification requirements. While this is welcome news for taxpayers, DPT will still have a far-reaching impact which many feel could undermine the OECD’s base erosion and profit shifting (BEPS) project. March 30, 2015

New German regulations on allocation of profits to permanent establishments

The Upper House of the German Parliament (Bundesrat) approved the regulations on the application of the arm’s-length principle to permanent establishments (PE regulations), which follow the authorised OECD approach (AOA). March 27, 2015


OECD paper on risk and re-characterisation could threaten arm’s-length principle says industry

Industry representatives are concerned about the continued viability of the arm’s-length principle in light of the OECD’s paper on risk and re-characterisation, released as part of the base erosion and profit shifting (BEPS) project. March 27, 2015

China’s SAT issues regulations on outbound service payments as part of crackdown on tax evasion

China’s State Administration of Taxation (SAT) recently issued a notice regarding payments involving related offshore parties. China has openly declared its plans to crackdown on tax evasion, so the issuing of new regulations come as no surprise. March 26, 2015


Taxpayers welcome Delhi High Court’s decision to strike out bright-line test for AMP expenses

The Delhi High Court issued a significant ruling concerning the taxation of advertising, sales, and marketing promotions (AMP) expenses. March 25, 2015

Rio Tinto fears OECD’s BEPS project will discriminate against multinationals and harm investment environment

Rio Tinto’s “taxes paid” report for 2014 revealed the company paid $ 7.1 billion worth of taxes and royalties globally. The report also voiced Rio Tinto’s concerns over the OECD’s base erosion and profit shifting (BEPS) project and the potential for discrimination against multinationals. March 24, 2015


Italian Supreme Court rules TP irregularities must be substantiated with clear avoidance behaviour

In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent. The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient grounds for an adjustment. March 19, 2015

EC reveals tax transparency measures and promotes automatic exchange of information as answer to tackling evasion

On March 18, the European Commission (EC) released its Tax Transparency Package which it hopes will serve as a tool for “healthier” tax competition and help member states recognise illicit tax practices. March 19, 2015


SKAT’s aggressive approach to transfer pricing leaves taxpayers fearing an anti-business agenda in Denmark

Danish tax authority, SKAT, collected DKK 20 billion ($2.9 billion) in tax adjustments in 2014 by challenging 76 companies’ transfer pricing arrangements. The agency’s aggressive tax policy has been widely criticised by business with suggestions that government has an anti-business agenda. March 18, 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


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


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