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A ruling by the Pune tribunal says that the revenue authorities in India must clearly demonstrate the appropriateness of a particular method when trying to make an adjustment based on the taxpayer's method choice. Vineet Chhabra and Viswanathan Subramaniam of Deloitte explain.
July 02, 2009
Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers.
July 01, 2009
The Australian Tax Office has been given more government money to tackle aggressive schemes as the onslaught on transfer pricing uses continues in the country.
July 01, 2009
Authors of a report on tax havens and development, commissioned by the Norwegian government, believe international action is required to deal with the problem of transfer mispricing.
June 30, 2009
Following a recent Indian tribunal ruling on the use of cash profit/sales, Samir Gandhi and Vineet Chhabra of Deloitte India explain the importance of profit level indicators (PLI) under the TNMM.
June 24, 2009
The latest rules on special tax adjustments were a hot topic when China’s State Administration of Taxation (SAT) held a half-day online question and answer session earlier this month.
June 24, 2009
TPWeek has joined Twitter, the micro-blogging and social networking site, to provide updates on the ever-changing world of transfer pricing.
June 23, 2009
The Amsterdam Court of Appeals hands victory to the taxpayer in a transfer of goodwill dispute, limiting the taxes payable. Eduard Sporken, and Jenny Theresia of KPMG discuss the case and its implications.
June 23, 2009
For companies that use transfer pricing to avoid paying tax, news that country-by-country reporting is on the agenda of a meeting of G20 finance ministers in Berlin next week is bad news.
June 17, 2009
Tarun Arora and Shikha Gupta of PricewaterhouseCoopers outline the problems apparent in the Indian transfer pricing rules and provide suggestions for improving the regulations in the coming budget.
June 17, 2009
What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form?
June 15, 2009
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Vu Tran and Alexander Gurevich of PricewaterhouseCoopers in the US discuss how the change from US GAAP to IFRS will affect cost sharing arrangements
July 01, 2009
We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation?
July 01, 2009
Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation.
June 30, 2009
Governments should abandon the arm’s-length price and grant multinationals the discretion to set their own transfer prices internally, says a report from the Rotman School of Management at the University of Toronto.
June 24, 2009
The State Administration of Taxation in China has ordered the provincial and local level tax authorities to initiate a nationally coordinated campaign of tax investigations on operators of highways.
June 24, 2009
The Australian Taxation Office (ATO) has released an external review of the advance pricing arrangement (APA) programme together with an initial response to the recommendations contained in the report.
June 23, 2009
The Sultanate of Oman has finally released details for the country’s first ever set of transfer pricing rules.
June 22, 2009
Michael D’Ascenzo, commissioner of the Australian Tax Office stressed that companies should practice good corporate governance that takes into account tax risks.
June 17, 2009
Danny Beeton and Hannah Carter of Grant Thornton in the UK explain how the decision in the DSG case is potentially a turning point in transfer pricing economics, at least in the UK
June 17, 2009
Cristiane Magalhães and Fábio Lima da Cunha of Machado Associados in Brazil report on how the authorities have been using information not accessible to taxpayers to determine arm’s-length prices.
June 15, 2009
The economic and technological development zone office of the Beijing Municipal State Tax Bureau (BSTB) has signed its first unilateral advanced pricing agreement (APA) after various rounds of negotiations.
June 11, 2009
Slovakia and Spain have both introduced amendments to bring their legislation into line with the EU transfer pricing forum’s approach to documentation.
November 26, 2008
On November 6 2008, the Taiwan Ministry of Finance released the final ruling to the modifications of the safe harbour ruling (ruling number 09704555160). The finalised ruling modifies the conditions which must be met for profit seeking enterprises to prepare transfer pricing contemporaneous documentation
November 26, 2008
New guidance from China’s State Administration on Taxation (SAT) means that parent companies will now need signed agreements with subsidiaries for service costs to be deductible.
November 25, 2008
Paul Flignor and Alan Granwell of DLA Piper investigate four of the major economic considerations for companies as a result of the OCED draft report.
November 25, 2008
China was supposed to have mandatory documentation as of January 1 2008 but the final guidelines are still awaited. Here, Glenn DeSouza summarises the hot issues and shares strategies on dealing with thin capitalisation and documentation.
November 25, 2008
Brazilian transfer pricing rules adopt fixed profit margins in methods applicable to import transactions. Fabia Moreira Azevedo of Machado Associados explains why many are critical of the percentage profits margins allowed under the rules
November 18, 2008
Batanayi Katongera of Thomson Reuters warns corporations everywhere that business restructurings are under more scrutiny than ever before in light of the OECD discussion draft on the topic.
November 18, 2008
Russia’s weak transfer pricing regime is hindering the countries development and making the country less attractive to foreign investment, says a leading professional firm
November 03, 2008
The Inland Revenue Authority of Singapore (IRAS) has published a draft supplementary circular to provide guidance on the application of the arm’s length principle to related party loan and service arrangements.
October 28, 2008
The new tax treaty between Spain and Colombia contains transfer pricing implications. Here Moises Curiel and Diego Gonzalez-Bendiksen of Baker & McKenzie outline the treaty elements.
October 22, 2008
Transfer Pricing Associates, an independent provider of global transfer pricing and valuation services, is establishing operations in two new jurisdictions.
July 02, 2009
Freshfields Bruckhaus Deringer gives Danny Beeton the nod as the firm’s head of transfer pricing economics.
July 01, 2009
Diane Hay has been appointed international tax special adviser at PricewaterhouseCoopers in the UK
May 21, 2009
Michael Velten, Angie Ng and Penelope Wong move on from Transfer Pricing Associates in Asia.
May 18, 2009
US law firm DLA Piper has expanded its transfer pricing practice with the appointment of three new specialists: two principal economists and one of counsel.
April 22, 2009
Chinese officials finally announce details of the changes to be made to transfer pricing rules
December 03, 2008
Slovakia and Spain have both introduced amendments to bring their legislation into line with the EU transfer pricing forum’s approach to documentation.
November 26, 2008
On November 6 2008, the Taiwan Ministry of Finance released the final ruling to the modifications of the safe harbour ruling (ruling number 09704555160). The finalised ruling modifies the conditions which must be met for profit seeking enterprises to prepare transfer pricing contemporaneous documentation
November 26, 2008
New guidance from China’s State Administration on Taxation (SAT) means that parent companies will now need signed agreements with subsidiaries for service costs to be deductible.
November 25, 2008
Russia’s weak transfer pricing regime is hindering the countries development and making the country less attractive to foreign investment, says a leading professional firm
November 03, 2008
The introduction of thin capitalisation to the new Chinese Corporate Income Tax Law (CIT) was celebrated by many borrowing enterprises, but many will be left disappointed by its lack of clarity
October 28, 2008
Carlos Eduardo Costa MA Toro and Carlos Eduardo de Biasi of Zilveti Sanden Advogados believe that new rules on requesting a reduction in the presumed profit margin are a step forward for Brazilian transfer pricing
October 22, 2008
The Bangalore Tax Tribunal has ruled in favour of the taxpayer in a dispute that covered the powers of a transfer pricing officer to disregard a company’s transfer pricing analysis.
September 30, 2008
Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process
September 02, 2008
Glenn DeSouza, managing director, TP Management Consulting, Shanghai, and Benjamin Cheong, intellectual property group, Baker & McKenzie, Hong Kong believe you have to consider the tax implications when seeking to protect your intellectual property in China
August 13, 2008
A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP Week.com lists more than 350 cases.
August 07, 2008
Denso Corporation has revealed that Japanese tax authorities have demanded about ¥7.3 billion ($68 million) in transfer pricing surcharges from the company
July 09, 2008
PricewaterhouseCoopers Canada outlines the main points in the Glaxo Canada ruling
June 19, 2008
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