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

Brazil
1%
Russia
16%
India
18%
China
17%
South Africa
48%


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Luxembourg better defines TP rules amid EC investigations

Luxembourg’s government has presented a draft budget to Parliament which includes changes to the transfer pricing rules. October 22, 2014

Interest deductions: the new war on base erosion

The G20 and OECD's Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are different from where the underlying economic activity takes place. October 22, 2014


IFA speakers address lack of progress in OECD’s intangibles work

Defining intangibles is vital to the success of the OECD’s BEPS project because a clear definition is important for comparability and valuation. However, given the broad range of intangibles, deciding on one precise definition will be extremely challenging. October 21, 2014

Why taxpayers must resign themselves to increasing levels of public disclosure

At the 68th IFA Congress in Mumbai panelists warned that taxpayers will need to prepare themselves for decreasing confidentiality levels in relation to company data. October 17, 2014


Double Irish is on borrowed time

The Irish government announced in its 2015 Budget the abolition of the double-Irish structure and its intention to introduce an income-based system for the taxation of intellectual property, which it is calling a Knowledge Development Box. October 17, 2014

Bombay High Court rules in favour of Vodafone in TP share value controversy

The Bombay High Court (HC) has ruled in favour of Vodafone India in relation to a transfer pricing dispute between the company and the tax authorities about whether the transfer of shares between the company and a subsidiary in Mauritius constituted a transaction that gave rise to income tax. October 13, 2014


India: Transfer pricing aspects of restructuring

Ever since the inception of the transfer pricing (TP) regulations in India, tax authorities have become increasingly vigilant when scrutinising the inter-company transactions and TP policies of multinationals (MNE), resulting in increased intensity of TP audits and a huge quantum of TP adjustments close to $37.21 billion (to date). October 10, 2014

Industry calls for deferral of GAAR in India over fears country is not ready

General anti-avoidance rules (GAAR) could come into effect from April 1 2015 but there is a chance the rules will once again be deferred as a result of opposition from the tax industry and corporates. October 09, 2014


Local employment motivated Apple Ireland tax deal but it’s an isolated case

The EC is investigating tax arrangements between Ireland and Apple because it thinks the tech company was given a financial advantage in exchange for creating jobs. October 07, 2014

OECD BEPS Action 8 and the need for market data

The OECD’s most recent release, Guidance on Transfer Aspects of Intangibles, specifically Action 8 under OECD BEPS plan, brings to the fore the need for market data. October 07, 2014


ATO TP staffing issue is being “overblown”

Australian media has reported that the country’s tax office (ATO) is experiencing staffing issues in the transfer pricing department, which is impacting taxpayers, but advisers have said this is an overstatement. October 07, 2014

The Italian approach to intercompany loans

The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. October 06, 2014


BEPS deliverables increase uncertainty over future of arm’s-length standard

The recently released BEPS deliverables have generated more confusion than certainty, specifically with regards to the OECD’s plans for the arm’s-length standard. October 01, 2014

Indian government and taxpayers split over OECD’s plans to make tax arbitration binding

The Indian government announced its opposition to the OECD’s proposal to resolve disputes with mandatory arbitration, claiming that it will infringe on the country’s national rights. September 30, 2014


Why tax inversions have been so prevalent in the life sciences industry

Tax inversions have been rife throughout all industries but none more so than in life sciences. The structure of life sciences companies and the ease at which intellectual property (IP) can be moved contribute to the industry’s suitability for tax inversions. September 26, 2014

Unanswered questions on the digital economy drive scepticism over OECD’s BEPS progress

Advisers and taxpayers have voiced their concerns about the questions which still remain unanswered in the BEPS disclosure documents at TPWeek and International Tax Review’s 14th Global Transfer Pricing Forum in Washington, DC. September 23, 2014


Bob Stack reiterates arm’s-length standard and supports need for CbCR

Bob Stack, deputy assistant secretary (international tax affairs), US Department of Treasury, has spoken publicly in the wake of last week’s BEPS document releases. September 23, 2014

US Treasury official speaks out against patent boxes

Bob Stack, deputy assistant secretary (international tax affairs), US Department of Treasury, has spoken out against other countries’ use of patent box regimes in a speech following the BEPS document releases last week. September 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


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