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

Brazil
1%
Russia
13%
India
15%
China
13%
South Africa
58%


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Leading Canadian transfer pricing cases favour domestic rules over OECD guidelines

Until the decision in the GlaxoSmithKline (Glaxo) case, all previous Canadian court decisions had slavishly applied the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. How do the guidelines now fit into the law and a practical strategy of establishing the correct transfer prices? August 21, 2014

Profit splits and value chain analysis key to addressing transfer pricing issues in the digital economy

Paul Morton, head of group tax for Reed Elsevier, writes about the transfer pricing methodologies required for a rapidly developing digital economy. August 18, 2014


IRS roadmap makes way for flexibility in TP audit process

The IRS transfer pricing audit roadmap was created to improve the efficiency and consistency of transfer pricing audits, placing greater emphasis on the process of individual cases. August 14, 2014

Singapore: Transfer pricing aspects of restructuring

By Luis Coronado and Stephen Lam, Ernst & Young Singapore August 14, 2014


Russia: Transfer pricing aspects of restructuring

By Evgenia Veter, Steve Cawdron and Anuar Mukanov of EY Russia August 08, 2014

New CFC rules exclude transfer pricing adjustments from profits generated abroad

Alterations made to controlled foreign corporation (CFC) legislation in Brazil will have a significant impact on the way taxpayers look at foreign profits. August 08, 2014


China shows signs of OECD guideline acceptance

China has demonstrated a certain degree of resistance towards the OECD guidelines and adopting international policies but it is beginning to show signs of acceptance. August 07, 2014

Americas Awards 2014 nominations released

The nominations for the Americas Tax Awards, which take place in New York on September 18, have been announced. August 07, 2014


Incomplete intangibles guide suggests OECD’s September deadline was overly ambitious

On July 23, Michelle Levac, chair of Working Party No 6, announced that the revised chapter on intangibles, to be released in September, will not be final guidance. August 05, 2014

EC investigations suggest weakening control of tax authorities

The European Commission (EC) announced recently that it has opened three in-depth investigations into supposed sweetheart deals between the tax authorities of Ireland, the Netherlands and Luxembourg with Apple, Starbucks and Fiat. The investigations are looking into whether the deals comply with EU rules on state aid. July 31, 2014


Controversial inversions driven by lack of US tax reform

Inversion deals between companies such as Medtronic and Covidien, and failed attempts such as Pfizer’s desired takeover of AstraZeneca, have brought inversion transactions to the forefront of global tax issues. While the US government argues that inversion deals are anti-competitive, many taxpayers feel they are faced with an unappealing US tax system and have no choice but to look elsewhere. July 29, 2014

Why Finnish Supreme Court denied OECD guidelines

Janne Juusela, Jarno Mäkelä and Lauri Ahokalli of Borenius Finland discuss how a landmark decision by the Finnish Supreme Administrative Court (SAC) on transfer pricing reclassified the OECD’s reference to debt-to-equity. July 24, 2014


Italy: Transfer pricing aspects of restructuring

By Piergiorgio Valente, Valente Associati GEB Partners. July 23, 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


New global head of tax and TP at Rosen Group

April 03, 2014

Joe Andrus's replacement as head of transfer pricing at OECD named

Joe Andrus, head of the transfer pricing division of the OECD, announced he would be leaving his post last year. His replacement has now been named. April 03, 2014

New partner at BMR & Associates

April 17, 2014

AlixPartners expands transfer pricing practice

May 14, 2014

KPMG expands TPDR practice

May 29, 2014

Ryan acquires Altus International

June 04, 2014


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