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Poll

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

Brazil
1%
Russia
18%
India
19%
China
19%
South Africa
43%


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Content

Germany’s increasingly tough TP audit environment presents challenges for taxpayers

Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. December 19, 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


Hickman’s TP challenge at the OECD and his post-BEPS plan

The OECD’s transfer pricing baton has now been passed over to Andrew Hickman, formerly a transfer pricing partner at KPMG in the UK, who has spoken exclusively with TPWeek of his trepidation about taking on such a demanding role and what he hopes the next TP project will be. December 16, 2014

India’s ITAT hands control back to tax authority in Vodafone case

The Income Tax Appellate Tribunal (ITAT) has asked the income tax (IT) department to review its valuation of Vodafone’s taxable income. December 15, 2014


The battle ahead for India Shell

The defence team involved in the India Shell case provide a breakdown of the litigation so far and a look forward for the company’s court battle. December 15, 2014

Luxembourg releases paper on tax transparency amid “Lux leaks” controversy

On December 10 the Luxembourg Ministry of Finance released proposals relating to tax transparency and advance rulings. This move comes as no surprise in the light of the recent “Lux leaks” scandal and appears to be a strategic attempt at advertising Luxembourg’s willingness to fight tax evasion. December 11, 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

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

Attack on incentivised regimes will force tax industry to re-examine value chain management

The risks versus people functions debate has long been a bone of contention in the tax world. The OECD’s BEPS project has signalled a drastic shift towards people functions, which means taxpayers and tax authorities will have to rethink value chain management. December 08, 2014


Uncertainty around definition of key people functions could leave taxpayers in hot water

One of the main concerns voiced on the first day of the Global TP Forum 2014 in Singapore was the definition of key people functions in relation to BEPS and the scope for interpretation. December 05, 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


SARS looks to APAs to create smoother TP audit process and tackle mispricing

The South African Revenue Service (SARS) has announced it is considering introducing an advance pricing agreement (APA) system in the hope of creating a quicker, more effective transfer pricing audit process. November 27, 2014

Why Singapore risks losing top spot in Asia for regional headquarters

Singapore risks losing its reputation as the best place in Asia to set up regional headquarters because of planned changes to tax rules and competition from Hong Kong and Malaysia. However, industry professionals in Singapore have been quick to quash these claims. November 27, 2014


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

EC investigations could negatively impact legitimate TP arrangements

The European Commission’s (EC) investigations into deals made with Starbucks, Fiat and Apple have left the tax world fearing a witch hunt, which could cause perfectly legitimate transfer pricing agreements to suffer. November 25, 2014


ATO’s reconstruction ruling likely to increase uncertainty and compliance risks for taxpayers

The Australian Taxation Office (ATO) has finalised transfer pricing ruling TR 2014/6, which outlines the application of reconstruction provisions. November 25, 2014

Pascal Saint-Amans responds to criticism of TP arbitration work

Pascal Saint-Amans, director for the centre for tax policy and administration at the OECD, has responded to claims the OECD’s work on TP arbitration is moving too slowly. November 20, 2014


Shell still holding-up against Indian authorities in transfer pricing share dispute

Shell has won its most recent court battle with the Indian authorities in the Bombay High Court over its issuance of shares to a local entity, which the authorities have tried to claim additional income tax over. November 19, 2014

Merck Group’s Frank Schoeneborn discusses patent box controversy, negative press and issues of confidentiality

Frank Schoeneborn, head of operational transfer pricing at Merck Group, discusses the power of public opinion and the impact it is having on transfer pricing in an interview with TPWeek. November 19, 2014


Merck Group’s Frank Schoeneborn on patent boxes, people functions and profit splits

Frank Schoeneborn, head of operational transfer pricing at Merck Group, shares his views on BEPS progress, issues of confidentiality and the increasingly negative press transfer pricing is receiving. November 19, 2014

Public registry of beneficial ownership in Denmark shows continuing trend

The Danish government, on November 7, announced plans to create a public registry of beneficial ownership. November 17, 2014


Greek Ministry of Finance issues templates and guidelines for advance pricing agreement negotiations

In an effort to provide taxpayers with an integrated procedural framework for the negotiation of advance pricing agreements (APAs), the Greek Ministry of Finance recently released template application forms for both preliminary consultations and formal negotiations, as well as additional guidelines on the overall APA procedure. November 17, 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


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