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Chinese related party transactions annual reporting forms finalised

Steven Tseng and Cheng Chi of KPMG detail the latest changes in China January 06, 2009

How exchange rate differences arise in related-party transactions in Poland

Taxpayers may have to explain why they used a certain exchange rate in related-party transactions. If they cannot they could face higher tax bills, explain Jarosław Bieroński and Bartłomiej Biały of Sołtysiński Kawecki & Szlęzak December 23, 2008

China issues disclosure forms

Taxpayers in China will need to submit nine transfer pricing disclosure forms when they file their 2008 tax return next year December 19, 2008

Global documentation burden increases

The burden of keeping up with transfer pricing documentation requirements is becoming one of the biggest challenges for multinational corporations, with some taxpayers having to prepare upwards of 500 transfer pricing reports a year December 17, 2008

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Convergence of customs valuation and transfer pricing

Tax authorities around the world are beginning to note the importance of looking at both transfer pricing and customs valuations when assessing multinational companies’ operations. January 06, 2009

Indian authorities tell officers to apply transfer pricing rules in bank-branch dealings

The banks' compliance burden is set to increase after an order from CBDT December 19, 2008

How the recession will have an impact on comparables selection and documentation

It is now clear to tax authorities and taxpayers, says Pamesh Sharma of Thomson Reuters, that the economic downturn will offer unique challenges to the arm’s-length standard and the continuing search for evidence to support expected profit levels by economic function. December 17, 2008


More countries comply with EU documentation rules

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

New Taiwanese safe harbour ruling and its implications

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

China service fees charged between parent and subsidiaries examined

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

Economic issues in the OECD draft report on business restructurings

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

Zero hour on transfer pricing in China

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

Advisers criticise profit margin in resale price less profit method

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

Business restructuring is under the transfer pricing spotlight

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 must strengthen transfer pricing rules

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

Singapore proposes transfer pricing guidance for loans and services

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

Double taxation treaty between Spain and Colombia approved

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


KPMG strengthens transfer pricing practice in China

KPMG’s global transfer pricing services practice transfers two key figures and promotes another in the China team. January 06, 2009

Transfer Pricing Associates bolsters Asia team

Transfer Pricing Associates (TPA) has appointed Michael Velten to its Asia team. Velten will lead the firm's global financial services practice and will be based in Hong Kong January 06, 2009

KPMG recruits for transfer pricing practice

Stephanie Pantelidaki will join KPMG’s transfer pricing team in London as an associate partner December 22, 2008

Ceteris hires three and expands practice into Boston

Ceteris, a global economic consulting firm that provides transfer pricing, intellectual property and valuation services has expanded into the Boston area by hiring Jill Weise and Mark Bronson as managing directors, and Kate Sullivan as a director November 04, 2008

Gardere adds transfer pricing managing director

An experienced Japanese professional has joined the Texas firm October 28, 2008


Officials discuss how transfer pricing will change in China

Chinese officials finally announce details of the changes to be made to transfer pricing rules December 03, 2008

More countries comply with EU documentation rules

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

New Taiwanese safe harbour ruling and its implications

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

China service fees charged between parent and subsidiaries examined

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 must strengthen transfer pricing rules

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

Thin capitalisation adopted in China

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

New Brazilian rules clarify how to obtain changes in profit margins

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


Bangalore Tribunal overturns official’s action

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

How the UK’s new approach to transfer pricing will work

Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process September 02, 2008

How you can protect IP and optimise your tax position in China

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


Turkey Transfer Pricing Documentation Guide

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

Ecuador transfer pricing documentation guide

Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador August 21, 2008

Ukraine transfer pricing documentation guide

Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine June 23, 2008

Finland transfer pricing documentation guide

Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year April 24, 2008

Malta transfer pricing documentation guide

Mirko Rapa, of PricewaterhouseCoopers in Valetta, describes the regime for transfer pricing documentation in Malta April 15, 2008


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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