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Poll

How do you rate your relationship with your CFO

Very good, they understand TP requirements well enough
8%
Good but there's room for improvement
31%
Good but TP is not their main concern
51%
They do not understand the requirements of the TP department
10%


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Content

Incoming transfer pricing regulations in Chile

The Chilean government sent a tax reform proposal to Congress on April 30 to generate additional revenues to increase expenditures in social development programmes such as the educational system, employment, economic growth and human development of most vulnerable sectors of society. May 18, 2012

Malaysia’s income tax and transfer pricing rules are retrospective

Taxpayers in Malaysia must ensure their transfer pricing is backed-up by contemporaneous documentation after the country retrospectively amended its transfer pricing regulations. May 17, 2012


Why Australia’s about-turn on permanent establishment policy means further uncertainty

Despite the Australian authorities promoting the separate entity approach during the OECD’s project on permanent establishments (PE), the Treasury now looks to be doing an about-turn in favour of the single entity approach, which advisers say is creating confusion and uncertainty amongst taxpayers. May 17, 2012

South Africa’s Magashula to hammer construction industry on tax avoidance

Oupa Magashula, the commissioner for the South African Revenue Service (SARS) has said they are discovering an increasing number of tax avoidance schemes through cross-border structuring, particularly by the construction industry. May 15, 2012


Why transfer pricing is on the up in Asia

Transfer pricing was a recurring concern for taxpayers attending the International Tax Review Asia Tax Forum in Singapore last week, emerging from every panel. May 15, 2012

Asia reacts to the arm’s-length principle

Asia is seen as less tolerant of the OECD's thinking on transfer pricing, compared to Europe and the Americas, but the region’s acceptance of the arm’s-length principle (ALP) is growing, say speakers at International Tax Review’s Asia Tax Forum in Singapore this week. May 09, 2012


Why US taxpayers should take confidence from Microsoft ruling

Microsoft’s recent US transfer pricing victory should force states to rethink the practice of outsourcing transfer pricing assessments, say advisers. May 08, 2012

Indian government names members of international tax and TP board

The Indian Ministry of Finance has set up an advisory group for international taxation and transfer pricing to reduce litigation and bring certainty for taxpayers operating in India. May 04, 2012


UK revises claims for group loss relief

HM Revenue and Customs (HMRC) has recently revised the guidance in its manuals regarding revisions to claims for UK group loss relief following mutual agreement procedure (MAP) settlements. May 04, 2012

Guatemala latest developing country to pass transfer pricing legislation

Guatemala has passed transfer pricing legislation which will start in 2013. The rules will adhere, generally, to the OECD transfer pricing guidelines. May 03, 2012


Third party audit firms mean more litigation for taxpayers

US states are employing third party audit firms to conduct transfer pricing assessments on a contingency fee basis, which is leading to more aggressive audits, and companies must devote more resources to state documentation in response. May 03, 2012

Why there is no short answer to the viability of the arm's-length principle

Is the arm’s-length principle enough? The short answer is not quite, but when you put multinational companies, tax campaigners, OECD officials and economists in the same room, there is never a short answer. May 03, 2012


How Zambian mining companies are undervaluing minerals

Mining companies in Zambia are still able to limit their taxable profits in the country, despite transfer pricing legislation, through undervaluing metals and minerals that are not traded on the global market. May 01, 2012

Drive for transparency is doomed, says SAB Miller

SAB Miller told ministers at the UK’s International Development Committee (IDC) that capacity building is essential if developing countries are to collect the right amount of tax but the “transparency drive to achieve a right outcome is, we believe, doomed”. May 01, 2012



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

How taxpayers can jeopardise their transfer pricing documentation

Taxpayers are preparing higher proportions of their own transfer pricing documentation before handing over to their advisers but certain important factors are being overlooked. February 28, 2012

Pepsi fights Indian tax authorities over Rs1 billion

Pepsi Foods’ stay of application with the Indian legal system over a demand of Rs1.04 billion ($21 million) has been disposed by the Income Tax Appellate Tribunal (ITAT) but an appeal date has been set. February 21, 2012

Why country by country reporting is not compatible with transfer pricing realities

An estimated $110 billion disappeared because of transfer mispricing on the import of crude oil in the EU and US between 2000 and 2010, a recent report from Publish What You Pay (PWYP) Norway said. February 17, 2012

Common mistakes transfer pricing advisers make when dealing with the authorities

Your transfer pricing advisers provide the local link between your company and the tax officials working in every operational jurisdiction. An Italian revenue official explains the common mistakes advisers can make and how communications can be improved. February 16, 2012

Why taxpayers should stop using residual pricing methods in Portugal

The Portuguese tax authority has turned its transfer pricing focus to residual pricing methods, meaning companies should stop using them if they want to save money. February 02, 2012


India introduces APA programme at last

The Indian government has announced an advance pricing agreement (APA) programme to be introduced into its tax system in its budget announcement today. March 16, 2012

China’s SAT gives overview of anti-avoidance initiatives

The State Administration of Taxation (SAT) in China has provided an overview of anti-avoidance initiatives. February 29, 2012

British industry calls on government to extend scope of patent box

The Confederation of British Industry (CBI) sent its submission to the Treasury today in anticipation of the 2012 budget. February 22, 2012

New UK CFC rules put emphasis on significant people functions

The long-awaited draft UK controlled foreign companies (CFC) legislation was published in December 2011 with additional guidance and updated draft legislation issued on January 31 2012. The proposed rules affect transfer pricing by placing a new emphasis on significant people functions. February 15, 2012

BREAKING NEWS: The US budget and its TP implications

The Obama Administration released the proposed Fiscal Year 2013 Budget of the US government yesterday. Aaron Bone and Katherine Kimball, of Charles River Associates in San Diego, provide a commentary on its transfer pricing implications. February 14, 2012

UK concludes patent box consultation

The UK government has concluded its consultation on a proposed patent box. It is hoped it will encourage investment and economic growth in the UK and prevent innovative businesses moving intellectual property (IP) offshore. February 10, 2012


How transfer pricing advisers are responding to changes in service demand

Previously, TPWeek reported on multinationals’ decrease in demand for outsourced transfer pricing advice. Advisers explain how they are keeping up with market trends and how the approach of accountants and lawyers varies. February 07, 2012

How to avoid the application of the Brazilian resale price minus method

Experts are applying a new technique to avoid the application of the Brazilian resale price minus method. February 01, 2012

Clashes between customs and transfer pricing law highlighted in Korean case

A recent ruling by the Tax Tribunal of Korea said companies that make transfer pricing adjustments after reporting importation to customs will not be refunded. January 05, 2012

Alberta Printed Circuits to be OECD example

The OECD is considering the Canadian Alberta Printed Circuits transfer pricing dispute as a case study in its intangibles project, according to the company’s expert witness. December 13, 2011

Reed Elsevier explains its practical issues with IP

While all taxpayers deal with intellectual property (IP), and the evaluation issues surrounding it for taxation purposes, some taxpayers place more value on it than others. Paul Morton, the head of tax for publishing house, Reed Elsevier, explains the practical day-to-day problems surrounding IP, when operating on a global scale. December 08, 2011


Irish transfer pricing documentation guide

By Barbara Dooley and Gavan Ryle of PwC, Dublin. June 23, 2011

Ecuador transfer pricing documentation guide

Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador March 23, 2011

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

China and Hong Kong transfer pricing documentation guide

Steven Tseng, Chi Cheng, Kari Pahlman and Nathan Richards of KPMG China outline the transfer pricing documentation guidelines in Hong Kong and China. March 29, 2010

Germany transfer pricing documentation checklist

Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime. March 08, 2010

Japan transfer pricing documentation guide

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

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

Singapore transfer pricing documentation guide

Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore. February 22, 2010

South Korea transfer pricing documentation guide

Tae-Yeon Nam, Dong-Jun Yeo and Stefan Moller, Kim and Chang, Seoul July 14, 2009

Argentina transfer pricing documentation guide

Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers February 11, 2009


Double tax treaties and transfer pricing in Poland

Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008

Double tax treaties and transfer pricing in Ecuador

Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping June 05, 2008

Double tax treaties and transfer pricing in Brazil

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

Double tax treaties and transfer pricing in Peru

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

Double tax treaties and transfer pricing in India

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


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

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