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

South Africa

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Why investors are pushing for transparent tax planning

The transparency of multinationals’ tax practices is a growing concern for investors because reputational damage from transfer mispricing can negatively affect share prices. November 26, 2015

OECD debated necessity of cost contribution chapter in BEPS

In an interview with TPWeek, Andrew Hickman, head of the OECD’s transfer pricing unit, said the OECD debated whether a chapter on cost contribution arrangements was necessary in the final BEPS guidance released last month. November 25, 2015

How OECD’s Andrew Hickman is managing the final BEPS guidance

Andrew Hickman, head of the OECD’s transfer pricing unit, has been responsible for producing a large proportion of the OECD’s final BEPS guidance. November 24, 2015

Negotiating transfer pricing and customs value

As international transfer pricing activities attract even more scrutiny, more attention is also being paid to customs regimes, and how they contribute to the transfer price. November 24, 2015

Why taxpayers see the TATA ruling as a breakthrough for Indian TP disputes

In a transfer pricing dispute between TATA Consultancy Services and the deputy commissioner of income tax (DCIT) the Income Tax Appellate Tribunal (ITAT) has ruled that assessment officers (AO), should use their own mind rather than automatically transferring cases to transfer pricing officers (TPO). November 24, 2015

Pfizer merges with Allergan to take advantage of inversion deal worth $155 billion

US multinational, Pfizer, has merged with Allergan, based in Ireland, creating the world’s largest pharmaceutical company by sales. November 23, 2015

How MAP is slowing down and disappointing taxpayers

Mutual agreement procedures (MAP) are in place to resolve double taxation disputes, however the time it takes to find a resolution has led to a worldwide backlog of cases. Transfer pricing practitioners discuss their experiences. November 19, 2015

How small businesses can adopt multinational tax practices

Small business owners in a British town have joined together to try to emulate multinational tax practices. November 17, 2015

Spanish High Court rules in favour of Dutch Bank

The Spanish High Court (AN – Audiencia Nacional) has ruled the Spanish authorities’ adjustment of Dutch Bank’s transfer pricing methods was wrong, stating that the OECD 2008 Model Tax Convention could not apply to documentation filed before 2008. November 12, 2015

More audits expected as Vietnam establishes dedicated TP inspection department

The General Department of Taxation (GDT) in Vietnam has established a Transfer Price Inspection Department, a step that continues the authorities’ recent focus on transfer pricing activity. November 12, 2015

HMRC initiating fewer transfer pricing reviews

HM Revenue & Customs (HMRC) has confirmed it is initiating fewer transfer pricing review cases with corporate entities in a Freedom of Information Act (FOIA) request submitted by TPWeek. November 10, 2015

Pascal Saint-Amans against patent boxes: The next step for IP regimes

Pascal Saint-Amans discussed the OECD’s dislike for patent box regimes at a Thomson Reuters news event last week. November 10, 2015

US to implement country by country reporting for 2016

The USA is moving towards implementing country-by-country-reporting (CbCR) with the first reports likely to be required for the 2016 tax year. November 05, 2015

How Brazil is cherry picking BEPS recommendations

Brazil, as a non-OECD member, seems to be cherry picking the BEPS recommendations that suit its regime, rather than accepting the full package. November 03, 2015

Taxpayers must act now to manage implications of EU auditor independence regulations

The EU has approved legislation which imposes mandatory audit firm rotation and restrictions on non-audit services to public interest entities (PIE). November 03, 2015

Chevron loses multi-million dollar transfer pricing court case

The Federal Court in Australia has ruled that Chevron Australia did not prove the interest rate on a loan to its US partner company was at arm’s-length. Chevron now owes the ATO AUS $300 million ($213 million). October 29, 2015

Belgian tax official reveals details on new transfer pricing documentation requirements and BEPS plans

In a BEPS seminar organised by the Federation of Enterprises in Belgium this week, with a special focus on the practical consequences for Belgian enterprises, a representative of the Belgian Ministry of Finance, Steven Van Elsuwé, provided more details on the new legislative proposals that have been prepared so far, and on the different options that are currently under review. October 28, 2015

Anything other than arbitration

In its final BEPS release the OECD removed the recommendation for mandatory arbitration after objections from non-member developing countries. The option of arbitration remains under discussion, however, at UN Tax committee. October 27, 2015

Limiting base erosion involving interest deductions and other financial payments

The OECD recommended approach is to limit interest deductions based on a fixed percentage of between 10% and 30% of EBITDA. HM Treasury responded this week by issuing their consultation document outlining 18 questions for consideration. October 26, 2015

India provides final rules on use of range concept and multiple year data

The Indian government has finally published a notification on the introduction of the range concept in its Income Tax Law, 16 months after it was initially announced. October 26, 2015

BEPS for the retail industry

There are specific issues related to the final BEPS guidance for the retail industry. October 26, 2015

Why alleviation of double taxation is not keeping pace with BEPS work

Taxpayers are becoming concerned the OECD’s aim to alleviate double taxation is being out-paced by the BEPS work. Isabel Verlinden, Patrick Boone, Gaby Bes, and David Swenson of PwC explain why this concern is justified. November 26, 2014

Consensus over definition of intangibles and location savings increasingly unlikely

Action 8 of the OECD’s BEPS project on the transfer pricing aspects of intangibles aims to achieve universal consensus over definition. However, this is beginning to look like an impossible task, with influential BRIC countries such as India, making their own interpretations. December 10, 2014

Asia transfer pricing special focus

Transfer pricing in Asia is a rapidly developing market for taxpayers, their advisers and the authorities. TPWeek held its third annual Global Transfer Pricing Forum in Singapore on December 2&3 with a record turn-out from delegates and featuring two keynote speeches from OECD officials. December 17, 2014

China’s APA stats show acceptance of different TP methods

China’s State Administration for Taxation (SAT) released its advance pricing agreement (APA) statistics for 2013 on December 5 2014. January 12, 2015

Taxpayers criticise Chinese regulations

China’s transfer pricing regulations, which were published on January 9, will affect how companies manage their tax affairs and add to their compliance costs, say tax directors February 11, 2020

Singapore updates its transfer pricing guidelines

The Singapore revised transfer pricing (TP) guidelines, published January 6 2015, require taxpayers to prepare and maintain contemporaneous TP documentation to support TP positions and have this in place by the time the company’s tax return is filed. January 19, 2015

New TP reforms in Ukraine likely to ramp up disputes and prolong audits

The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pricing control. January 14, 2015

China focuses on cross-border transactions in war on tax evasion

The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. The move signals a crackdown on profit shifting, which could see cross-border transactions increasingly scrutinised. January 12, 2015

Lack of transfer pricing rules leads to questionable audits in Hong Kong

Despite a self-touted reputation as a leading global financial centre, Hong Kong’s Inland Revenue Department (IRD) has been criticised by tax practitioners for overly aggressive audits on asset managers. Hong Kong has limited transfer pricing legislation and often seeks to enforce arm’s-length pricing through practice notes and a network of tax treaties. January 08, 2015

The transfer pricing implications of the Italian regional tax on productive activities

The provincial tax court of Reggio Emilia has issued ruling No 510/03/14 relating to the Italian regional tax on productive activities (IRAP). January 06, 2015

Reduction in maximum income tax rate for inclusion in Brazil’s black and grey lists

The Brazilian Ministry of Finance has issued Portaria MF no. 488/2014, on December 1, which reduced the maximum income tax rate from 20% to 17% for the purposes of applying the concepts of tax havens and privileged tax regimes. December 08, 2014

Swedish Tax Agency reviews TP legislation and proposes changes

The Swedish Tax Agency has, on request by the Swedish Government (Ministry of Finance), evaluated the transfer pricing documentation rules’ functionality and proposed possible changes to simplify the application. December 08, 2014

The dangers of creating an accidental PE and how to avoid it

As companies’ employees become more globally mobile, there is an increasing risk that a permanent establishment (PE) may occur unintentionally, leaving taxpayers at risk of taxable income liabilities. November 28, 2014

Determining the transfer pricing policy for liquefied natural gas

Tamir Druz, a director at Capra Energy Group, discusses the best methods for determining an optimal transfer pricing policy for liquefied natural gas (LNG). September 01, 2014

Hong Kong signs first bilateral APA

Hong Kong has agreed its first bilateral advance pricing agreement (APA) since its scheme began in March 2012. EY, who facilitated the deal between Hong Kong and the Netherlands, explain how the process progressed with the authorities. July 10, 2014

Marzen Aluminum ruling based on structuring rather than pricing

The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The ruling is significant because it is the first Canadian decision focusing on the structuring of transactions rather than the pricing. June 26, 2014

Netherlands reclaims Swiss company’s profits and applies penalties in transfer pricing case

The Dutch District Court of Zeeland/West-Brabant ruled, on January 17 2014, on a Swiss Captive Insurance company (without employees), taxing most of its profits back in the hands of a related Dutch taxpayer with 50% penalties. March 18, 2014

Intangible assets in the media and entertainment industries: In depth analysis

The US television production industry reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look at dealing with intangibles. February 18, 2014

The transfer pricing considerations of Suzuki’s 100% subsidiary in India

Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implications, which must be considered by any multinational in this position. February 04, 2014

McKesson Canada: CRA wins in Tax Court but taxpayer files with Court of Appeal

The Canada Revenue Agency (CRA) saw pharmaceutical company McKesson’s arguments dismissed by the Tax Court in December 2013 but the company has now filed its arguments with the Federal Court of Appeal. January 24, 2014

How to organise your TP department to avoid dispute

Governments' hard-line approaches to companies' transfer pricing arrangements has resulted in a rise in transfer pricing cases being resolved in court, explains Fabrizio Lolliri, European director of transfer pricing for Hogan Lovells. January 21, 2014

The new cost of global compliance: Private company data for local comparables

All of us in the tax world know that transfer pricing has been a hot topic this year. Around the globe, tax authorities have become more aggressive, primarily to reduce government fiscal deficits. January 20, 2014

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

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

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

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