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Revenue authorities struggle to alter method applied

A ruling by the Pune tribunal says that the revenue authorities in India must clearly demonstrate the appropriateness of a particular method when trying to make an adjustment based on the taxpayer's method choice. Vineet Chhabra and Viswanathan Subramaniam of Deloitte explain. July 02, 2009

Taxpayers face difficulties in tackling customs and transfer pricing

Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers. July 01, 2009

ATO given extra funding to combat abuses

The Australian Tax Office has been given more government money to tackle aggressive schemes as the onslaught on transfer pricing uses continues in the country. July 01, 2009

Norwegian report attacks transfer mispricing

Authors of a report on tax havens and development, commissioned by the Norwegian government, believe international action is required to deal with the problem of transfer mispricing. June 30, 2009

Tribunal reaffirms the importance of comparability

Following a recent Indian tribunal ruling on the use of cash profit/sales, Samir Gandhi and Vineet Chhabra of Deloitte India explain the importance of profit level indicators (PLI) under the TNMM. June 24, 2009

SAT answers questions on anti-avoidance administration

The latest rules on special tax adjustments were a hot topic when China’s State Administration of Taxation (SAT) held a half-day online question and answer session earlier this month. June 24, 2009

TPWeek joins Twitter

TPWeek has joined Twitter, the micro-blogging and social networking site, to provide updates on the ever-changing world of transfer pricing. June 23, 2009

Landmark decision in Amsterdam court case on business restructuring

The Amsterdam Court of Appeals hands victory to the taxpayer in a transfer of goodwill dispute, limiting the taxes payable. Eduard Sporken, and Jenny Theresia of KPMG discuss the case and its implications. June 23, 2009

Country-by-country reporting could end transfer pricing misuse

For companies that use transfer pricing to avoid paying tax, news that country-by-country reporting is on the agenda of a meeting of G20 finance ministers in Berlin next week is bad news. June 17, 2009

How the budget could reform transfer pricing

Tarun Arora and Shikha Gupta of PricewaterhouseCoopers outline the problems apparent in the Indian transfer pricing rules and provide suggestions for improving the regulations in the coming budget. June 17, 2009

TPDoctor: Mexico annual tax return change

What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form? June 15, 2009

Content

IFRS will affect cost sharing arrangements

Vu Tran and Alexander Gurevich of PricewaterhouseCoopers in the US discuss how the change from US GAAP to IFRS will affect cost sharing arrangements July 01, 2009

TPDoctor: Chinese Sanlaiyibu company

We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation? July 01, 2009

France introduces tougher transfer pricing rules

Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation. June 30, 2009

New report tells governments to abandon arm’s length price

Governments should abandon the arm’s-length price and grant multinationals the discretion to set their own transfer prices internally, says a report from the Rotman School of Management at the University of Toronto. June 24, 2009

China targets highway operations companies

The State Administration of Taxation in China has ordered the provincial and local level tax authorities to initiate a nationally coordinated campaign of tax investigations on operators of highways. June 24, 2009

ATO set to update APA program

The Australian Taxation Office (ATO) has released an external review of the advance pricing arrangement (APA) programme together with an initial response to the recommendations contained in the report. June 23, 2009

Oman issues details on new transfer pricing rules

The Sultanate of Oman has finally released details for the country’s first ever set of transfer pricing rules. June 22, 2009

D’Ascenzo warns taxpayers against aggressive transfer pricing

Michael D’Ascenzo, commissioner of the Australian Tax Office stressed that companies should practice good corporate governance that takes into account tax risks. June 17, 2009

DSG: a turning point in transfer pricing economics

Danny Beeton and Hannah Carter of Grant Thornton in the UK explain how the decision in the DSG case is potentially a turning point in transfer pricing economics, at least in the UK June 17, 2009

Authorities use confidential information to ascertain prices

Cristiane Magalhães and Fábio Lima da Cunha of Machado Associados in Brazil report on how the authorities have been using information not accessible to taxpayers to determine arm’s-length prices. June 15, 2009

First unilateral APA signed in Beijing

The economic and technological development zone office of the Beijing Municipal State Tax Bureau (BSTB) has signed its first unilateral advanced pricing agreement (APA) after various rounds of negotiations. June 11, 2009


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


TPA moves into Turkey and South Africa

Transfer Pricing Associates, an independent provider of global transfer pricing and valuation services, is establishing operations in two new jurisdictions. July 02, 2009

Freshfields appoints head of transfer pricing economics

Freshfields Bruckhaus Deringer gives Danny Beeton the nod as the firm’s head of transfer pricing economics. July 01, 2009

Hay lands role at PwC

Diane Hay has been appointed international tax special adviser at PricewaterhouseCoopers in the UK May 21, 2009

Three leave TPA Asia

Michael Velten, Angie Ng and Penelope Wong move on from Transfer Pricing Associates in Asia. May 18, 2009

Clarke Norton and team join DLA Piper

US law firm DLA Piper has expanded its transfer pricing practice with the appointment of three new specialists: two principal economists and one of counsel. April 22, 2009


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

Arbitration Commission cases soar

A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP Week.com lists more than 350 cases. August 07, 2008

Denso gets transfer pricing charge in billions

Denso Corporation has revealed that Japanese tax authorities have demanded about ¥7.3 billion ($68 million) in transfer pricing surcharges from the company July 09, 2008

Glaxo Canada: the key issues

PricewaterhouseCoopers Canada outlines the main points in the Glaxo Canada ruling June 19, 2008


Argentina transfer pricing documentation guide

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

China transfer pricing documentation guide

Steven Tseng and Chi Cheng, KPMG China January 21, 2009

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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GLOBAL TAX RECRUITMENT
  • Transfer pricing careers in Asia
    A career in transfer pricing has always afforded the luxury of flexibility, with professionals enjoying the opportunity of internal secondments all around the world. Some destinations have traditionally had more appeal than others, with the last five years seeing a particular rise in opportunities to work in Asia.