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Under pressure from countries who view Ireland as a soft touch for aggressive tax planning, Ireland has introduced new transfer pricing rules in its new Finance Bill.
February 05, 2010
Taxpayers face an additional administrative burden under changes to appendix 9 of the Multiple Information Tax Return (DIM), but the acceptance of electronic filings for certain companies will speed up the process of submitting returns.
February 03, 2010
Indonesia’s head of transfer pricing has told a seminar of tax professionals the criteria used for initiating an audit, amid increased scrutiny from the country’s tax authorities.
February 03, 2010
Eduard Sporken and Paul Kraan of KPMG Meijburg & Co explain the changes made to the European arbitration convention.
February 01, 2010
The Indian government has finally confirmed that the country’s new dispute resolution panel is not mandatory, contrary to what taxpayers were led to believe.
January 29, 2010
China has released a tax circular that closes a loophole in the country’s thin capitalisation rules regarding the deduction of interest payments.
January 27, 2010
Hasnain Shroff and Vinita Chakrabarti of KPMG in India look at the Global Vantedge case.
January 27, 2010
Whether existing methods of resolving transfer pricing disputes are suitable for use in developing countries was the subject of an interesting panel at the UN expert group meeting on transfer pricing.
January 21, 2010
How the UN transfer pricing manual should tackle documentation requirements was the subject of a spirited panel on the second day of the meeting of experts.
January 21, 2010
In a bid to keep as much money as possible in the local economy as possible, the Ecuadorian government has issued a new reform to tax law, which includes an exemption from the transfer pricing regime for companies that comply with certain conditions.
January 20, 2010
In a frank discussion at a UN meeting of experts, panellists expressed their frustrations about all the available transfer pricing methods.
January 19, 2010
The first panel of a group meeting on transfer pricing at the UN saw a robust argument over the merits of the formulary apportionment method against the arm’s-length principle.
January 19, 2010
TPWeek will be reporting from the first UN meeting focusing on transfer pricing.
January 18, 2010
Chemical company Innospec Limited has signed a £3.9 million ($6.5 million) agreement with HMRC in settlement of transfer pricing disagreements.
January 18, 2010
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The special bench of Chandigarh Income Tax Appellate Tribunal has re-stated the critical importance of conducting a detailed FAR analysis.
February 04, 2010
The European Court of Justice (ECJ) has upheld a discrepancy in Belgium’s transfer pricing rules, even though it represents a restriction on the EU freedom of establishment.
February 03, 2010
Hasnain Shroff, A Pradeep and Vinita Chakrabarti of KPMG India discuss taxpayers' relief over finding out that the use of the new Indian dispute resolution mechanism is optional.
February 02, 2010
The Canada Revenue Agency (CRA) has increased the number of cases accepted in its advance pricing agreement (APA) programme, but the average time for closing cases has also risen.
January 28, 2010
Taxpayers and advisers believe yesterday’s discussion document on controlled foreign companies reflects a genuine attempt by the UK tax authorities to respond to their concerns.
January 27, 2010
Luiz Felipe Ferraz of Demarest e Almeida in Sao Paulo discusses the nuances of Brazilian tax reforms as an important reform was brought in then quickly reversed in late 2009.
January 27, 2010
Speakers had much to say about the abuse of the tax rules in less sophisticated jurisdictions during a meeting of a UN transfer pricing group meeting this week.
January 21, 2010
Providing adequate education to tax authorities in developing countries is vital when developing transfer pricing systems, according to panellists at the UN group meeting on transfer pricing.
January 21, 2010
International Tax Review will present its fifth annual European Tax Awards at the Dorchester Hotel in London on May 18 2010
January 20, 2010
Specialists at a UN meeting have stressed the importance of building transfer pricing units within the tax authorities of developing nations.
January 19, 2010
A discussion about country by country reporting caused a heated debate at a meeting at the UN this week
January 20, 2010
Changes to Taiwan’s tax law mean that gains from structured notes are no longer regarded as interest income and so should be liable for withholding tax.
January 18, 2010
Alexander Voegele and Hendrik Fuegemann of NERA Economic Consulting outline how new administrative guidelines are affecting taxpayers’ application of the relocation of functions regulations in Germany
October 01, 2009
China’s State Administration of Taxation (SAT) has issued a circular that identifies transfer pricing audit targets and specifically provides directives relating to special inspections of non-resident enterprises
September 09, 2009
India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules
September 08, 2009
The Venezuelan tax authorities have stepped up their attempts to generate extra tax revenue by targeting the transfer pricing methodologies of large automotive and pharmaceutical companies
September 02, 2009
Changes to India’s transfer pricing rules crucial for taxpayers.
September 01, 2009
In the current environment, multinational companies and their tax and transfer pricing advisers face unprecedented challenges, Clarke Norton, principal economist at DLA Piper in New York, identifies some transfer pricing opportunities.
August 19, 2009
Ceteris, a global economic consulting firm, has hired a partner of Ernst & Young to set up its transfer pricing practice in New Zealand.
February 02, 2010
Salim Rahim is now a partner in the Washington, DC office of Baker & McKenzie.
January 14, 2010
John Woodruff joins Gardere Wynne Sewell as a partner in the tax practice group in the Houston office.
January 06, 2010
Charlene Unitan has set up a transfer pricing boutique called UNITAX.
December 15, 2009
Cameron McKenna has continued the trend of law firms hiring transfer pricing expertise.
December 07, 2009
Vispi Patel has left his role as head of direct tax at Economic Laws Practice in Mumbai
November 18, 2009
True Partners Consulting International network, an association of tax consulting firms in select markets around the world, has added three new affiliates.
November 17, 2009
Garrigues has appointed three new international tax and transfer pricing partners.
November 11, 2009
Decree number 392/009 amends and clarifies some of the detailed regulations established by decree number 56/009, which was issued in January 2009.
October 05, 2009
Alexander Voegele and Hendrik Fuegemann of NERA Economic Consulting outline how new administrative guidelines are affecting taxpayers’ application of the relocation of functions regulations in Germany
October 01, 2009
A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of goods purchased by Brazilian legal entities and packed or repacked locally for resale.
October 01, 2009
Loss-making documentation is a catch-22 situation in China. Glenn DeSouza, managing director at Transfer Pricing Management Consulting in Shanghai, which has an exclusive strategic alliance with Baker & McKenzie, explains the difficulties
September 17, 2009
India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules
September 08, 2009
The introduction of new transfer pricing documentation rules has led to taxpayers facing more frequent and detailed audits of their activities than ever before.
August 12, 2009
The US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties
September 08, 2009
What does the introduction of advance pricing arrangements mean for taxpayers in India?
September 01, 2009
In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing.
September 01, 2009
In a series of amicus briefs filed with the US Court of Appeals for the Ninth Circuit, several powerful groups have expressed their support for Xilinx in the latest phase of its battle with the Internal Revenue Service.
August 25, 2009
An important concession helpful to manufacturers using mainland China contract processors has been denied.
August 19, 2009
What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn?
August 17, 2009
Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers
February 11, 2009
Steven Tseng and Chi Cheng, KPMG China
January 21, 2009
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
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador
August 21, 2008
Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine
June 23, 2008
Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year
April 24, 2008
Mirko Rapa, of PricewaterhouseCoopers in Valetta, describes the regime for transfer pricing documentation in Malta
April 15, 2008
Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing
June 03, 2008
Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping
June 05, 2008
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
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
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
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
Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta
April 15, 2008
Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process
April 07, 2008
Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit
April 06, 2008
Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland
March 14, 2008