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Australia boasts impressive advance pricing agreement (APA) statistics. To ensure they stay ahead, the Australian Tax Office (ATO) is planning a significant overhaul of the system, a government spokesperson explains. September 06, 2010
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On August 30 2010, the Indian government tabled a Direct Tax Code Bill 2010 in the parliament. The new code aims to replace the Income Tax Act 1961 and the Wealth Tax Act 1957. If enacted, it will be effective from April 1 2012. September 01, 2010
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The report from the Joint Committee on Taxation (JCT) on President Obama's 2011 budget, provides revenue estimates for each of the tax provisions in the budget, including proposals about transfer pricing and treatment of intangibles. August 31, 2010
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The Canadian mutual agreement procedure (MAP) programme saw an increase in the number of accepted and completed cases in the past year. August 19, 2010
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Tatiana Villani and Anna Cecília Brasil of Machado Associados comment on the main differences between Brazil’s transfer pricing rules and the OECD’s guidelines, and the difficulties and opportunities that this may create for taxpayers. August 17, 2010
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The OECD has approved updates to the Transfer Pricing Guidelines in its first major revision since they were released in 1995. July 28, 2010
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A new circular telling local tax bureaux to carry out a nationwide evaluation of taxpayers’ 2008 and 2009 contemporaneous transfer pricing documentation (CTPD) was released on July 12 by the Chinese tax authorities. July 28, 2010
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Cristiane Magalhães and Victoria Rozsavolgyi Bortolin of Machado Associados advise taxpayers in Brazil on when it is best to look for alternative methods to use when establishing transfer prices. July 27, 2010
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The Australian government hopes to use international information exchange as part of an increased scrutiny of transfer pricing arrangements. July 13, 2010
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Helga Marie Andresen and Merethe Bryn of Deloitte in Norway discuss the court’s ruling in the landmark case of ConocoPhillips, which shifted the tax authority’s approach to evaluating whether Norwegian companies receive their part of the profit compared to the group as a whole. July 12, 2010
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The Delhi High Court has issued a landmark ruling providing guiding principles on the applicability of the arm’s-length standard to the realm of marketing intangibles. July 12, 2010
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Fashion retailer, H&M, has been criticised for its operations in Bangladesh and tax payments amounting to transfer mis-pricing. July 07, 2010
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Gianmarco Monsellato and Sylvain Chevrier of Taj, a member of Deloitte Touche Tohmatsu, answer commonly asked questions about the implementation of the new French documentation rules. July 06, 2010
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The Chinese tax authorities have identified transfer pricing and anti-avoidance as their main priorities for 2010 and have begun to target to specific industries. July 06, 2010
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Taxpayers are looking into how a common corporate tax base might affect transfer pricing after a new report into how to complete the EU single market lent support to the plans of Algirdas Šemeta, European commissioner for tax, to introduce a proposal on the measure. July 06, 2010
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The Brazilian Congress has passed thin capitalisation rules that will affect the deductibility of interest payments, among other things. July 05, 2010
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Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil. June 30, 2010
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Bruce Clements of Kennesaw State University discusses the dangerous area of establishing an economic connection with States in the second of a three-part discussion of state and local considerations in US business planning. June 28, 2010
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The Indian government has released a revised discussion paper on the controversial Direct Tax Code (DTC) containing several provisions that will affect transfer pricing. June 23, 2010
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The UK coalition government’s first budget contained some provisions that will interest transfer pricing practitioners and cause alarm among the financial industry in particular. It also raised the prospect of a general anti-avoidance rule in the UK. June 23, 2010
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Eduard Sporken and Neil Schaatsbergen provide background information on APAs/ATRs in the Netherlands and comment on the related statistics recently published by the Dutch tax authorities. June 22, 2010
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China and India have leapt up the table to join Japan at the top of the latest TPWeek poll to find the most aggressive transfer pricing officials in the world. June 16, 2010
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Samir Gandhi, Manisha Gupta and Radhi Raman of Deloitte in India discuss the overzealous use of penalty provisions in the country. June 16, 2010
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In Tax Briefing Issue 07 of 2010, released on June 10, the Irish tax authorities have issued guidance on the documentation that is required from taxpayers to comply with the new transfer pricing rules. June 15, 2010
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The OECD will review and revise its transfer pricing guidance on intangibles later this year in an effort to clarify one of the most frustrating and notoriously inconsistent areas of international tax. June 10, 2010
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A mutual agreement between the Netherlands and the US which amends the procedure of obtaining an exemption from dividend withholding tax under the Netherlands-US tax treaty makes sense as it affords the US government responsibility for deciding if US entities qualify for relief under the treaty. June 09, 2010
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Tax directors from multinational companies expressed alarm over shifts in transfer pricing trends during a panel at the joint American Bar Association and International Fiscal Association event in Copenhagen. June 09, 2010
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New transfer pricing rules failed to be passed into law within the Constitutional deadline, creating controversy as to which rule applies to transactions carried out since the beginning of the year. June 07, 2010
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A mutual agreement has been settled between the competent authorities of the Netherlands and the US which amends the procedure by which US pension funds obtain an exemption from dividend withholding tax under the Netherlands-US tax treaty. June 02, 2010
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Waman Kale and Vinita Chakrabarti report on a judgment by the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) relating to the information technology, business process outsourcing sector. May 27, 2010
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K R Girish and Rohan Phatarphekar of KPMG discuss the reported agreement reached by the Indian and US competent authorities. May 26, 2010
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The release of the first guidance on the use of the Thai advance pricing agreement (APA) system has been met with approval by advisers. May 26, 2010
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Cristiane Magalhães and Henrique Erbolato of Machado Associados Advogados e Consultores in Brazil discuss how the country's complex transfer pricing rules affect cost sharing agreements. May 24, 2010
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Bruce Clements, associate professor of accounting and taxation in the Michael J Coles College of Business at Kennesaw State University and practising CPA delivers the first of a three-part discussion of state and local considerations in US business planning. May 17, 2010
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Rohan Phatarphekar and Hasnain Shroff in India continue TPWeek’s discussion about the DRP process and expand on the practical implementation aspects. May 13, 2010
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A draft bulletin officiel des impôts released by the French tax authorities, intended to help taxpayers and practitioners understand the changes to transfer pricing rules in the country has instead deepened the confusion. May 12, 2010
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Rahul Mitra and Navneet Kothari of PricewaterhouseCoopers in India call for transfer pricing experts to be mandatorily involved in Dispute Resolution Panels (DRP) decisions. May 11, 2010
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The Australian government has enraged the mining industry with the announcement of a 40% super tax, in the Henry Tax review. The industry is now facing much larger tax burdens which will threaten the transfer prices in place on resources such as coal. May 10, 2010
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The International Tax Ruling office of the Italian Revenue Agency (IRA) has issued its first advance pricing agreement (APA) bulletin since the country’s APA programme became effective in 2005. May 05, 2010
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Milap Jain, India’s director general of international tax and transfer pricing, speaks exclusively to TPWeek about his priorities are for 2010 and beyond and how he hopes for greater cooperation with taxpayers. May 05, 2010
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A Chinese tax official has revealed plans to broaden the scope of the country’s anti-avoidance agenda and also provided important statistics from 2009. May 04, 2010
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Hernán Katz of Deloitte in Mexico describes how many transfer pricing difficulties faced by taxpayers in Latin America are linked to the lack of development in the regions’ financial markets. April 26, 2010
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Andréa de Oliveira Ramos and Cristiane Magalhães of Machado Associados in Brazil discuss the important idea of changing fixed profit margins that are used to calculate benchmarks in the country. April 26, 2010
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Gordon Hands of CUFTanalytics explains how taxpayers can assess the arm’s-length dividend rate for intercompany preferred share issuances. April 20, 2010
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Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo comment on increasing documentation burdens for taxpayers in Japan. April 16, 2010
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Batanayi Katongera of Olswang explores the practicalities of designing and implementing a dynamic global transfer pricing policy document. April 14, 2010
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Jacqueline Shek and Dawn Quek of Baker & McKenzie Hong Kong and Glenn DeSouza of TP Management Consulting in Shanghai evaluate some of the unusual aspects of departmental interpretation and practice note number 46 and assess its implications for companies operating in Hong Kong. April 14, 2010
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Gordon Hands of CUFTanalytics examines two example cases, an interest rate swap and a factoring transaction, where expected loss (EL) is used to price the credit risk portion of the intercompany financial transaction. April 14, 2010
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Jan-Paul Borman and Amit Chadha of PricewaterhouseCoopers in South Africa discuss how economic pressures and the recent budget have sharpened the tax authorities’ attentions on transfer pricing. April 12, 2010
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In March 2010 HM Revenue & Customs (HMRC) released an update of the guidance in its International Manual on the UK’s thin capitalisation rules. This guidance is prepared primarily to assist inspectors of taxes in applying the thin cap legislation, but also offers useful insights into HMRC policy for taxpayers and advisers. April 07, 2010
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Sanjay Sanghvi and Daksha Baxi discuss the landmark E*TRADE litigation and its implications for the India-Mauritius tax treaty. April 06, 2010
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Gordon Hands of CUFTanalytics discusses the merits of external credit ratings and forward-looking probability of default as credit risk measures when selecting comparable uncontrolled financial transactions (CUFTs) April 06, 2010
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The tax burdens of overseas fee payments from China have unavoidably increased due to the recent issuance of circulars and tax reforms, a leading tax professional has said. March 31, 2010
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The US Advance Pricing Agreement (APA) Program has announced it received 127 applications for agreements last year, only four more than in 2008. And yet, the time taken to process important bilateral APAs has increased by more than four months. March 31, 2010
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Fabia Azevedo and Cristiane Magalhães of Machado Associados in Brazil explain how importers can make use of letters of credit to avoid double taxation where country agreements do not help. March 25, 2010
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Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo discuss why Japan continues one of the most challenging jurisdictions for tax and transfer pricing in the world. March 09, 2010
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Purvez Captain and Steven Wrappe of Ernst & Young discuss the advantages and problems that can be found in adding to in-house professionals’ responsibilities. March 08, 2010
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With increased audit activity and recent tax litigation in Canada, determining the arm’s-length pricing of guarantees continues to be a difficult transfer pricing issue and risk for multinationals. Gordon Hands of CUFTanalytics discusses the issues raised in the GE Capital Canada’s guarantee fee transaction litigation. March 01, 2010
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Advisers from Machado Associados summarise the new Brazilian transfer pricing rules and tax deductibility requirements. February 25, 2010
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Amr El Monayer, assistant to the deputy minister of the Egyptian Ministry of Finance explains what the new guidelines will cover, and when they will be released. February 25, 2010
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Hasnain Shroff, A Pradeep and Vinita Chakrabarti highlight the key transfer pricing aspects that need attention in the forthcoming Union Budget 2010. February 24, 2010
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Professionals harbour fears over inconsistent implementation across Europe and some go so far as to question whether the system change was necessary. February 17, 2010
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AJ Bamidele of the Nigerian Federal Inland Revenue Service explains to TPWeek how Nigeria administers its transfer pricing regime. February 17, 2010
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The proposed revisions to chapters I-III of the OECD transfer pricing guidelines have been largely welcomed by transfer pricing practitioners, who feel they address more accurately the business environment. January 27, 2010
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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
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The Indian government has issued Press Note number 8, modifying the foreign technology agreement/collaboration policy wherein all payments towards royalties, lump-sum fees for transfer of technology and payments for the use of trademarks or brand names will be allowed to be paid without any restrictions.
January 04, 2010
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Tax authorities across the world are increasing their transfer pricing resources, issuing more penalties and preparing for a greater number of disputes, says a report by a leading tax advisory firm. December 18, 2009
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Charlene Unitan, formerly with Rolls-Royce and now with boutique firm UNITAX, warns companies to be aware of their tax risks and keep transfer pricing in check. December 16, 2009
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The Indonesian Tax Office (ITO or DGT) is proactively approaching taxpayers and requiring them to answer queries and questionnaires. December 10, 2009
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In a recent ruling, the AAR (Authority for Advance Rulings) in India held that transfer pricing provisions are only computational provisions and in the absence of charge of tax under any particular head of income specified in the Income tax Act, 1961 (the Act), transfer pricing provisions are not applicable. December 10, 2009
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The Indian tax authority has sent two senior tax officials to Mauritius and Singapore to ensure that tax treaty arrangements are being maintained. December 10, 2009
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On Friday, the Hong Kong Inland Revenue Department (IRD) released Departmental Interpretation a Practice Note (DIPN) 46, establishing the tax authority’s interpretation and practices on transfer pricing methodologies and related issues. December 07, 2009
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A report says that transfer pricing practices in the pharmaceutical industry will become more complex due to the economic and political pressures that companies in the sector are facing December 03, 2009
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Taxpayers in South America should expect greater scrutiny from the transfer pricing authorities in 2010, says a leading adviser. December 02, 2009
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India’s new dispute resolution mechanism has not got off to a good start. December 02, 2009
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The Indonesian government could reverse a key plank of its coal policy that was put in place to deal with transfer pricing abuses. December 02, 2009
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Twelve years after Brazil introduced transfer pricing laws and enacted the arm’s-length standard, Luiz Felipe Ferraz and Alexandre de S Almeida of Demarest e Almeida Advogados in Brazil assess whether the standard is being adhered to and what the future holds for transfer pricing in Brazil November 26, 2009
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The Indian Central Board of Direct Taxes (CBDT) has finally unveiled rules for the country’s new dispute resolution panels (DRP), nearly two months after the mechanism became effective. Samir Gandhi and Vineet Chhabra of Deloitte India discuss the rules notified by the CBDT. November 25, 2009
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Nonconforming transfer pricing rules in some Latin American countries are leading to problems with tax treaty negotiations November 23, 2009
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Wendy Nicholls and Leela Murugasu of Grant Thornton investigate how deep taxpayers must dive to find suitable comparables today. November 17, 2009
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Demet Tepe and Ken Kyriacou of Ernst & Young in Canada explain how companies must be aware of the effect making changes to the business to accommodate climate change initiatives can have on transfer pricing policies. November 09, 2009
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Spencer Chong, Cecilia Lee, Charles Chan and Paul Tang of PricewaterhouseCoopers describe how the situation for taxpayers has changed since the overhaul of the China’s transfer pricing rules. November 04, 2009
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Karl Gruendel and Ralf Heussner of Ernst & Young Shinnihon Tax explain the difficulties facing taxpayers with operations in Japan as the government struggles to find revenue sources. October 29, 2009
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Transfer pricing rules have created unwanted and unforeseen effects in Brazil over the decade they have been in force, presenting certain difficulties to the tax management and control of the operations carried out by multinational companies. October 29, 2009
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As transfer pricing continues to trouble taxpayers around the world, taxpayers are warned not to cut corners in their documentation when requesting APAs. October 22, 2009
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The number of advance pricing arrangements (APAs) has dropped in Australia, figures from the country’s tax authorities have revealed October 21, 2009
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The Danish tax authorities have recently issued new administrative guidelines on valuation and documentation of intellectual property (IP) transactions. October 15, 2009
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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
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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
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India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules September 08, 2009
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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
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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
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The Indian government will increase taxpayer confidence by allowing advance pricing agreements (APAs) for the first time, but concerns have been raised about how they will be implemented. August 18, 2009
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The new Direct Taxes Code tabled by the Indian finance minister has proposed some sweeping changes in the area of transfer pricing, explain Rohan Phatarphekar and Hardev Singh August 13, 2009
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Werner Stuffer and Susann van der Ham of PricewaterhouseCoopers in Germany discuss the increase of large transfer pricing audits in Germany August 11, 2009
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Four conglomerates being investigated by the Philippines Bureau of Internal Revenue (BIR) may find relief in the incomplete transfer pricing rules in place in the country. August 06, 2009
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In today’s environment, multinational companies are more than ever looking for ways to use taxation laws to help buoy their finances. August 06, 2009
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Lucia Fedina, Justen Ghwee, Juliane Keppler, and Gus Lee, of KPMG discuss how the global financial crisis has affected asset management transfer pricing. August 05, 2009
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A regulation released earlier this month by China’s State Administration of Taxation (SAT) makes loss-making single-function enterprises submit transfer pricing contemporaneous documentation to justify their losses. July 29, 2009
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On July 24 2009, the Hong Kong Court of Final Appeal (CFA) handed down its decision in the Ngai Lik Electronics Company vs CIR case. July 29, 2009
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A proposal from the Netherlands government makes it even more important for companies to have sufficient documentation in place to support the arm’s-length nature of inter-company financial transactions between Dutch and non-Dutch group companies. July 22, 2009
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Vineet Chhabra and Viswanathan Subramaniam of Deloitte India discuss the key budget amendments in the transfer pricing regulations and its implications on the taxpayers and the revenue authorities July 14, 2009
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After eight years of continuous controversy and adjustments, India’s government has outlined a reform package that aims to reduce the number of transfer pricing disputes in the country. July 08, 2009
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The general headquarters of the Italian Tax Police have issued a circular letter aimed at providing tax officers with updated instructions on the assessment activities they should perform. July 08, 2009
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Hardev Singh and Saurabh Dhanuka of KPMG highlight the key changes the Indian Union Budget 2009 makes to the transfer pricing and related provisions of the Income-tax Act, 1961 July 06, 2009
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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
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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
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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
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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
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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
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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
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Control over risk quickly became a significant point of discussion during a two-day public consultation on the transfer pricing aspects of business restructuring at the OECD in Paris this week June 11, 2009
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The Polish ministry of finance has published a document which identifies areas of possible tax fraud to be investigated, with the aim of raising revenues by catching the cheats. One of the priorities is transfer of income to related parties. June 10, 2009
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Transfer pricing has steadily become one of the number one issues for the Internal Revenue Service (IRS). Alfredo Jay Urquidi of Marsh & McLennan Companies and David Jarczyk of Ceteris discuss. June 09, 2009
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Joe Andrus and Irv Plotkin of PricewaterhouseCoopers explain how President Obama's recent budget may directly affect transfer pricing June 06, 2009
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The Hong Kong Inland Revenue Department has released a highly anticipated guidance document on transfer pricing and profit allocation. Travis Benjamin and Glenn DeSouza of Baker & McKenzie discuss the development. June 03, 2009
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The Russian tax authorities have issued a framework for the country’s long-awaited transfer pricing reform, meaning taxpayers will soon have to start revising their policies. May 27, 2009
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Transfer pricing rules in France face a dramatic overhaul, with stringent new documentation requirements and increased scrutiny on taxpayers expected. May 13, 2009
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The State Administration of Tax (SAT) in China has released two key circulars with important implications for transfer pricing investigation and follow-up measures. May 13, 2009
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Taxpayers might one day rely on a standardised set of documentation, prepared centrally, that is valid for all jurisdictions in which the company operates. But for now, advisers say companies must still be aware of regional differences. May 13, 2009
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Two cases before the Tax Court of Canada relate to financial transactions meaning taxpayers with intercompany financial transactions should be prepared for greater scrutiny under newly introduced reporting requirements. May 13, 2009
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Mark Atkinson and Richard Coombes of Deloitte in London believe that the decision in the first UK transfer pricing case in more than 20 years shows that taxpayers need a good reason to base a transaction in a low-tax jurisidiction May 01, 2009
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Exports made by a Brazilian company to offshore companies controlled by it, carried out in accordance with Brazilian transfer pricing rules, are analysed from a substance over form approach and regarded as sham transactions. April 29, 2009
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The Austrian Ministry of Finance discussed the appropriate interest rate when a group financing entity is located in a foreign low tax country in its annual tax meeting, meaning potential changes for taxpayers. April 28, 2009
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A UK company has been told that it has breached transfer pricing rules, but is unsure just how much it will have to pay HM Revenue and Customs April 23, 2009
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In a welcome move for multinational companies, the UK chancellor announced he will simplify the corporate gains rules for notional transfers within a group of companies April 23, 2009
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While many of the countries across the region claim to have rules that follow the OECD guidelines, experts take a different view. April 22, 2009
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The Danish tax authorities are demanding DKr3.6 billion ($637 million) in back taxes from a multinational company that it claims used aggressive transfer pricing to avoid paying the proper amount of tax April 15, 2009
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Taxpayers have told China’s State Administration of Tax that they are concerned about how to apply the new transfer pricing regulations during the economic downturn. April 09, 2009
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Egyptian taxpayers with related-party transactions will soon be required to provide a transfer pricing study to support such transactions under planned changes to the country’s tax laws. April 08, 2009
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Ireland will introduce a tax relief scheme for the acquisition of intellectual property, the country’s finance minster announced yesterday in his supplementary budget speech April 08, 2009
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It has been discussed whether Brazilian transfer pricing rules apply to the sale of shares and quotas held by Brazilian companies to a related party, as defined by law (including residents in low tax jurisdictions and beneficiaries of privileged tax regimes). April 03, 2009
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An Indian tax tribunal has said a taxpayer may have to change costs and profits on account of differences which arise in comparability analysis, but still referred the case back to a transfer pricing officer April 01, 2009
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Multinationals should reassess their advanced pricing agreements as the economic downturn puts pressure on existing transfer pricing models April 01, 2009
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After a fall in applications the previous year, more taxpayers filed for advance pricing agreements in 2008 in the US than in any other year in the history of the APA Program April 01, 2009
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Multinational companies have several different options to compensate controlled entities that own valuable intangibles used by other affiliates, explain Nobuo Mori, Vladimir Starkov, and Yuko Saito of NERA Economic Consulting March 25, 2009
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A Turkish construction company has won a case in Russia over when a permanent establishment (PE) is created.
March 19, 2009
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The poor state of the economy has led US advance pricing agreement (APA) program officials to become more open to modifying current and prospective APAs. However, no agreements have been changed yet. March 19, 2009
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The global economic downturn is putting corporate officers under extreme pressure. March 19, 2009
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Japan remains one of the most challenging tax jurisdictions, with transfer pricing enforcement being a focal point of the Japanese tax authorities. Both foreign and Japanese multinationals face increasing scrutiny and a heightened risk of transfer pricing audits and potential adjustments, explain Karl Gruendel and Rolf Heussner of Ernst & Young Shinnihon Tax. March 16, 2009
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Under long-anticipated regulations published by the US Internal Revenue Service (IRS), cost sharing arrangements (CSAs) remain an effective tool that multinational taxpayers can use to efficiently develop and manage ownership of valuable intangible property among subsidiaries. But valuations of pre-existing, platform intangibles contributed to CSAs will be scrutinised by the IRS going forward March 12, 2009
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The public comments in response to the OECD’s discussion draft on the transfer pricing aspects of business restructuring have been published on the Organisation’s website.
March 11, 2009
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Jersey and the UK signed a tax information exchange agreement today in London March 11, 2009
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A desperate budgetary situation could lead the Philippines government to finally introduce transfer pricing guidelines, three years after they were initially proposed. March 11, 2009
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Instructions for completion, guidance formats, and questionnaires related to the review by the registered external auditor (external CPA), and the electronic filing, of the financial audit report for 2008 were published in Mexico’s Federal Register at the end of February. The most relevant (and controversial) aspects of such instructions, formats, and questionnaires have to do with transfer pricing. March 11, 2009
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Taxpayers in China will need to ensure thorough documentation is in place for all transfer pricing after the authorities announced they will be tracking such filings electronically, making monitoring the information and pinpointing companies for audit easier. March 10, 2009
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A common intercompany transaction between multinational enterprises (MNEs) may result in unforeseen excise tax payments and late filing interest. Matthew Sambrook and Greg Noble of Ernst & Young in Canada explain the dangers. March 09, 2009
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Updated transfer pricing rules released on February 20 place a significant burden on both taxpayers and practitioners, beginning with the calendar year 2008. March 04, 2009
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A prominent UK newspaper ran a two-week expose on transfer pricing and international tax planning recently, attempting to name and shame some of the world’s leading multinational corporations. Aaron Leslie of TP International says the reaction was simplistic March 03, 2009
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A tribunal in India has ruled that payment of the arm’s length price to a dependent agent does not remove the tax liability of a foreign entities’ permanent establishment in India. February 25, 2009
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The issue of control was a key talking point at a conference on the transfer pricing aspects of business restructuring in London last week February 25, 2009
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The cost sharing regulations introduced recently in the US are extremely complicated but offer taxpayers many planning benefits according to one senior transfer pricing adviser. February 25, 2009
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Reliance on on the applicable federal rate (AFR) safe haven of section 1-482.2 of the Internal Revenue Code is not likely to address the need to comply with both US transfer pricing regulations and the expectation of the foreign tax authority that the interest rate on the intercompany loan be consistent with market interest rates for comparable loans February 24, 2009
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According to the explanatory statement of law number 9,430/96, which governs Brazilian transfer pricing rules, the lawmaker is focusing on avoiding tax evasion by means of undercharging exports or overcharging imports from a foreign related party February 17, 2009
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Uruguay has finally introduced guidelines on the application of transfer pricing rules, over two years after the laws were enacted. February 17, 2009
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Tax professionals in Australia agree with the authorities’ view of the value of the Administrative Appeals Tribunal’s judgement in the Roche Products case, though some would have preferred a more comprehensive ruling from the AAT February 11, 2009
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Taxpayers were warned of the UK government’s dual approach to disregarding transactions at a transfer pricing conference in New York last week. February 10, 2009
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Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HM Revenue & Customs in the UK tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority, offers taxpayers an insight into how transfer pricing cases are selected and talks about the future of transfer pricing. February 05, 2009
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On December 31 of each year, Brazilian legal entities must calculate transfer pricing adjustments in order to determine the taxable bases of the corporate income tax (IRPJ) and the social contribution on net profit (CSLL). February 02, 2009
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The new transfer pricing documentation-related penalty rules in the law for the coordination of international tax affairs (LCITA) are effective from December 26 2008. Under the new rules, a Korean taxpayer with related-party transactions is required to prepare and maintain contemporaneous documentation to avoid the 10% penalty on underreported tax. February 02, 2009
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A recent memorandum of understanding signed by the US and Germany has introduced a set of guidelines that set out how to utilise arbitration in advance pricing agreements. January 28, 2009
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Japan’s National Tax Agency (NTA) has issued a series of amendments to its existing administrative guidelines on transfer pricing, as well as the accompanying reference case studies. January 27, 2009
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Glenn DeSouza says China’s transfer pricing regulations are a good sign of economic development January 20, 2009
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On December 31 2008, the IRS issued new cost sharing regulations in temporary and proposed form. Mark Bronson of Ceteris explains what taxpayers should be doing to comply with the new rules January 20, 2009
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China’s State Administration of Taxation (SAT) released Circular Guoshuifa [2009] number 2 on January 8 2009 which finalised the implementation measures of special tax adjustments, a set of greatly anticipated new regulations on transfer pricing, to be effective starting this past year (FY2008). January 12, 2009
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An important decision by the High Court orders transfer pricing offices to conduct new assessments for several taxpayers. January 09, 2009
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Steven Tseng and Cheng Chi of KPMG detail the latest changes in China January 06, 2009
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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
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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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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
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HM Revenue and Customs in the UK has released draft legislation that amends the corporation tax rules on late-paid interest between connected companies. December 16, 2008
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One of the several controversial aspects of Brazil's transfer pricing legislation is the possibility for taxpayers to take into account the “basket approach” criterion to calculate the parameter price. Henrique de Freitas Munia e Erbolato of Machado Associados explains. December 16, 2008
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On July 17, the OECD issued its final report on the attribution of profits to permanent establishments, reaffirming the “separate entity approach” that hypothesises a permanent establishment (PE) as a separate and distinct enterprise that may deserve additional compensation according to the arm’s-length principle. The report notes, say Brandon Feldman and Patrick Breslin of the Ballentine Barbera Group, that the OECD transfer pricing guidelines should apply in such cases. December 16, 2008
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In less than a month, section 140A will be introduced into Malaysia's tax legislation. This new section in the income tax act, 1967 will specifically target transfer pricing issues. These changes will be effective from January 1 2009, so it is crucial that taxpayers understand the implications of the new transfer pricing provisions so that they can be adequately prepared. December 15, 2008
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On November 24 2008 the Polish President signed the act of November 6 2008 amending (among other things) the corporate income tax act. The new act introduces regulations concerning transfer pricing issues that will allow taxpayers to eliminate double taxation in transactions concluded with their foreign related parties. December 10, 2008
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The Philippines' wait for transfer pricing regulations is set to continue with the appointment of a new tax chief who, says tax professionals, is in no hurry to introduce any new rules. December 10, 2008
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Reforming transfer pricing in India will not be top of the agenda in next year’s budget, despite fears that the present system is too aggressive and a hindrance to business development. December 10, 2008
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Angelika Thies of CMS Hasche Sigle in Munich, Germany explains the latest developments in German transfer pricing December 10, 2008
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Following an amendment to the draft law entitled “Market Supervision Authority and other provisions” submitted to the Greek parliament, rules are being introduced for auditing transfer pricing in inter-company transactions. The rules are based on the OECD arm’s length principle December 04, 2008
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Chinese officials finally announce details of the changes to be made to transfer pricing rules December 03, 2008
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Advanced pricing arrangement programmes in Australia are expected to increase next year as taxpayers look for more certainty and the tax office enhances its transfer pricing review and enforcement activity December 03, 2008
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During economic downturns, US-based multinationals may find themselves wanting to repatriate cash from foreign subsidiaries. Under such circumstances, transfer pricing may provide a useful mechanism to achieve this in a tax-efficient manner. Mike Murphy, Albert Liguori and Julie Smith of Alvarez & Marsal Taxand explains how December 03, 2008
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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
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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
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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
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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
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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
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The French tax administration is increasingly turning to the transactional net margin method of determining an arm's length price. Jean-Luc Trucchi argues that rapidity and efficiency should not be used as an excuse for using a simplistic method that may generate a biased application of the arm’s length principle. November 21, 2008
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Countries in South-East Asia are introducing or reforming their transfer pricing rules to increase revenues and attract foreign investment November 19, 2008
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Hungary’s tax authorities have told taxpayers to comply with the country’s transfer pricing regime or risk facing large penalties November 19, 2008
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Atul Jain and Manisha Gupta of KPMG examine how the Indian tax authorities will approach modern business restructuring November 18, 2008
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In France, the concept of marketing intangible assets has led the tax authorities to imposing taxes on companies. Jean-Luc Trucchi explains what is happening. November 18, 2008
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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
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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
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Transfer pricing advisers in Thailand are warning companies using a specific holding company investment structure that traditional treatment of their tax liability is changing November 12, 2008
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Advisers expect President-elect Obama's administration to put changes to transfer pricing rules high on its list of priorities when he takes office November 11, 2008
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Rahul Mitra of PricewaterhouseCoopers outlines the flaws in the Indian transfer pricing regime and explains why changes need to be made to support multinational companies operating in the country November 10, 2008
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The Israeli Tax Authority (ITA) recently released the Income Tax Circular No. 3/2008 concerning transfer pricing November 05, 2008
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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
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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
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The Chinese State Administration of Taxation (SAT) is to be restructured to improve transfer pricing rules and enhance the tax administration of the country’s larger companies October 28, 2008
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Sweden tightens transfer pricing regulation October 28, 2008
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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
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The House of Commons public accounts committee report on the management of large business corporation tax stated that half the growth in global trade comes from transactions between subsidiaries of multinational companies October 28, 2008
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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
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Mary Bennett, head of the tax treaty and transfer pricing division at the OECD, has defended the discussion draft on the transfer pricing aspects of business restructuring October 22, 2008
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Daniel Rybnik of EnterPricing says that taxpayers in Argentina should be aware of the different treatment of transfer pricing policies based on variable and fixed factors October 22, 2008
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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
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Greg Noble and Alfred Zorzi, both partners at Ernst & Young in Canada summarise what the OECD business restructuring draft will mean for Canadian taxpayers October 20, 2008
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The Ministry of Strategy and Finance announces various proposed amendments to tax laws which include provisions to provide penalty relief to taxpayers maintaining contemporaneous transfer pricing documentation. October 17, 2008
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The Korean National Tax Service recently published its 2007 APA annual report, Henry An of Samil PricewaterhouseCoopers describes some of the key elements of the report October 15, 2008
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Santino Di Libero of Gowling Lafleur Henderson believes the inclusion of mandatory arbitration in the fifth protocol to the Canada-US treaty will help the competent authority process between the two countries October 15, 2008
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Transfer pricing rules have been in place in certain South America jurisdictions for many years but so far, little action has been taking by either taxpayers or the aurthorities. October 14, 2008
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Ramazan Biçer, senior transfer pricing specialist in the transfer pricing division of the Turkish revenue administration, highlights the key issues of advance pricing agreements in Turkey October 08, 2008
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The Netherlands has issued a new mutual agreement procedure (MAP) in a move that will make avoiding double taxation more accessible and transparent for taxpayers.
October 08, 2008
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On September 28 2008 Ecuador's president, Rafael Correa won a referendum on a new constitution that provides significant new powers, including some linked to transfer pricing.
October 08, 2008
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Harlow Higinbotham and Stuart Harshbarger of NERA Economic Consulting discuss the use of credit default swaps to price intercompany loan guarantees. October 07, 2008
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John Hughes of Mayer Brown explains how taxpayers must raise the bar on transfer pricing documentation to stay inline with the new OECD discussion draft. October 06, 2008
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Christopher Steeves of Fraser Milner Casgrain analyses the recent CRA report on the mutual agreement procedure program. October 05, 2008
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Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 05, 2008
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Taxpayers in South Africa have been pushing the boundaries of tax compliance by taking contentious positions on transfer pricing, the annual report of the South African Revenue Service (SARS) says. September 30, 2008
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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
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Chris Newman and Jon Jenni from Ernst & Young Shinnihon Tax, Tokyo describe possible changes to Japan’s transfer pricing legislation
September 29, 2008
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Patrick Breslin from The Ballentine Barbera Group reports on the potential problems of US-Chinese cost sharing arrangements
September 29, 2008
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Discussions on comparability and profit methods for transfer pricing purposes are set to continue after the OECD announced it would be holding face-to-face discussions with the business community.
September 25, 2008
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KR Girish and Hardev Singh of www.tpweek.com correspondents, KPMG, reveal why the Delhi Tax Tribunal sided with the taxpayer in a critical dispute over India’s safe harbour provisions September 25, 2008
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Batanayi Katongera, senior transfer pricing manager at Thomson Reuters, discusses why there soon could be a heightened interest in comparability analysis in transfer pricing documentation.
September 22, 2008
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The OECD Committee on Fiscal Affairs has released for public comments a discussion draft on the transfer pricing aspects of business restructurings. September 22, 2008
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Arbitration in transfer pricing is growing in importance and is becoming a popular alternative to litigation for tax authorities and taxpayers.
September 22, 2008
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Eduardo Goldszal, a partner at KPMG in Portugal highlights the main points of the country’s new APA legislation September 19, 2008
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New Zealand’s new double tax agreement with the Czech Republic has come into force as trade and investment between the two countries grows.
September 12, 2008
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The Indian government is set to decontrol the pricing of coal and give wide ranging powers, including determining transfer pricing in respect of captive coal and lignite (brown, lowest rank coal) mines, to the regulator.
September 12, 2008
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New transfer pricing rules introduced in June have caused an increase in audits in Brazil.
September 12, 2008
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An increasing number of countries worldwide are introducing transfer pricing rules in an effort to widen their tax bases and improve enforcement, says a report by KPMG.
September 11, 2008
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Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process September 02, 2008
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Peter Andersen of Transfer Pricing Associates highlights the contrast in the results for two taxpayers from Danish litigation over the use of price quotes in transfer pricing September 02, 2008
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The Bombay High Court has ruled that payment of arm’s length remuneration to a Dependent Agent Permanent Establishment (DAPE) in India extinguishes the tax liability of the foreign enterprise August 28, 2008
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TPWeek.com correspondent, Machado Associados, points out that rules on customs valuation and transfer pricing resemble each other in some ways, but diverge in others August 26, 2008
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Taxpayers should take a more systematic approach to setting and documenting inter-company transactions as tax authorities worldwide seek to apply transfer pricing regulations more stringently, a new study says.
August 20, 2008
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Key jurisdictions such as Belgium, China, Luxembourg and the US appear in the UK's tax treaty work plan over the next eight months August 20, 2008
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The IBON Foundation has hit out at oil companies’ reluctance to disclose how they determine what they charge for their products in the wake of windfall profits in the industry August 19, 2008
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TP Week.com correspondent Machado Associados points out that there is controversy about how the new definition of tax haven in recent changes to Brazil’s transfer pricing rules should be applied August 14, 2008
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US corporations are using transfer pricing regulations to move profits out of the country to avoid paying federal income tax, said a report from the US Government Accountability Office (GAO).
August 13, 2008
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The US tax court has ruled in a landmark decision that details of a significant transfer pricing court case will not be made public.
August 13, 2008
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The Inland Revenue Authority of Singapore (IRAS) is assessing how well taxpayers are complying with the country’s transfer pricing guidelines that were issued in 2006 by carrying out a transfer pricing consultation (TPC) programme.
August 07, 2008
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Russian Prime Minister Vladimir Putin has vowed to tighten transfer pricing regulations after he publicly accused one of the country’s leading steelmakers Mechel, of tax evasion.
August 07, 2008
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The UK tax authorities have proposed amendments to corporation tax rules on late payments of interest between connected companies August 07, 2008
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A global audit board has taken steps to tackle the involvement of related parties in major corporate scandals by releasing new guidance. July 30, 2008
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Steven Tseng, and George Bradt, of KPMG China, discuss the highly anticipated changes to China’s transfer pricing regulations July 30, 2008
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Karishma Popat and Fatema Hunaid from Grant Thornton India, identify recent developments in audits in the pharmaceutical industry transfer pricing audit in India July 30, 2008
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Italy is waiting to see if controversial changes made to the taxation of stock options, which could affect the Italian subsidiaries of foreign based parent companies, will be made permanent by the government. July 30, 2008
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Billions of dollars are at stake in transfer pricing disputes waiting to be resolved through the European Commission’s Arbitration Convention process July 14, 2008
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In the first in a series of keynote articles on the European Union Joint Transfer Pricing Forum, EUJTPF member Dirk van Stappen discusses its current focus June 26, 2008
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KR Girish and Hardev Singh, of TP Week correspondent KPMG in India, report that tribunal relied on Mentor Graphics decision June 23, 2008
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TP Week correspondent Machado Associados reports on safe harbour rules in the Brazilian transfer pricing regime June 19, 2008
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SUNAT issues guidance on filing dates for 2007 tax returns June 19, 2008
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CRA loses case to gain access to details on financial transactions June 19, 2008
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New guidance establishes rights and responsibilities of taxpayers June 19, 2008
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New regulations implement 2006 Income Tax law June 12, 2008
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Pharmaceuticals company could face massive tax bill
June 12, 2008
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Industry commentators focus responses on PE extensions June 12, 2008
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K R Girish and Rohit Jain, of TP Week India correspondent KPMG, report that slow and ineffective resolution of tax disputes has led to a growth in MAP June 11, 2008
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Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping June 05, 2008
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Maarten Koper and Susanne Verloove of Ernst & Young in Limassol on the interaction between tax treaties and transfer pricing rules in Cyprus June 04, 2008
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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
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Speaking of the controversial IRS win in the US Court of Appeals for the Ninth Circuit in the Xilinx case, IRS commissioner Douglas Shulman called the decision a “real victory”. June 04, 2008
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Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008
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Tax authority says it will concentrate on intangibles and restructuring June 02, 2008
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CRA audit focuses on Gildan’s offshore sales and marketing subsidiaries June 02, 2008
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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
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Inter-company services charges again under the transfer pricing spotlight May 27, 2008
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Philippines Bureau of Internal Revenue plans new revenue regulations May 23, 2008
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Rulings authority declares beer company must pay tax in India May 22, 2008
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Software corporation goes to court next month in the US
May 22, 2008
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Ludger Wellens and Irina Gerner of PricewaterhouseCoopers, TP Week’s correspondent in Germany, see potential disputes emerging May 21, 2008
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TP Week’s Brazil correspondent Machados Associados comments on the debate over the basket method May 21, 2008
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Responses to consultation paper support wide use of transactional profits methodologies May 15, 2008
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Brazil, South Africa and India propose joint approach on transfer pricing May 15, 2008
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Juan Carlos Ferreiro, of TP Week correspondent PricewaterhouseCoopers in Argentina, comments on the computerisation of transfer pricing information May 15, 2008
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Polish authorities step up scrutiny of related party documents in transfer pricing sweep May 15, 2008
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Natalia Valkovskaya, transfer pricing senior manager at KPMG in Moscow, describes the Russian government’s thinking May 12, 2008
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ATO reports faster conversion from risk reviews into fully fledged audits
May 08, 2008
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Zheng Li and Ted Keen, of CRA International’s London transfer pricing practice, argue that taxpayers can anticipate greater scrutiny May 01, 2008
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Ruling by Indian regulator could hit global pharmaceuticals companies May 01, 2008
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New communiqué gives taxpayers more time to file report April 28, 2008
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Five years of profits with Chinese joint venture company under scrutiny April 25, 2008
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Spot checks by Finnish tax authority on transfer pricing documents anticipated by advisers April 24, 2008
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Cargill case in India puts limits on scope of transfer pricing officers April 23, 2008
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Hardev Singh and Kishore Nair, of TP Week correspondent KPMG in India, say that further litigation is expected April 18, 2008
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Move quadruples transfer pricing expertise across sub-continent April 17, 2008
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New amendment gives SARS much wider authority on disclosure April 17, 2008
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Spanish National Court sets standard for intra-group services evidence April 14, 2008
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Indian government is more focused on general election, say local commentators April 10, 2008
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Jonathan Lubick, of Ballentine Barbera, and Henriette Fuchs, of Tadmor Attorneys, in Tel Aviv, examine similarities in approach April 10, 2008
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Catherine Snowdon, in New York, reports that unilateral APAs fell from 42 in 2006 to 26 last year
April 10, 2008
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KR Girish, of TP Week correspondent KPMG in India, explains why the Indian government's position fails to comply with international standards April 09, 2008
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Government aims to align requirements with other European countries April 07, 2008
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David Stavropoulos and Andrew Spalding, of Deacons law firm, say that the ruling illustrates Tax Office policy on future adjustments April 07, 2008
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Kim Jarrett and Mark Cormack of KPMG New Zealand contrast the tax authorities’ divergent approaches in Australia and New Zealand April 04, 2008
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Mining contracts come under renewed scrutiny in Congo April 03, 2008
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Commissioner revises tax bill on software licence earnings from 1999 to 2005 in groundbreaking ruling April 03, 2008
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Tynwald endorses seven-country package including transfer pricing agreements March 19, 2008
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Manuel Ángel Bouzas, of TP Week correspondent Garrigues, describes the process towards a new transfer pricing policy March 17, 2008
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Ernst & Young in Israel explains how companies deal with form 1385 March 14, 2008
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Joan Hortalà, tax partner, and Neus Mollera, associate, of leading Spanish law firm Cuatrecasas Abogados explain the environment for transfer pricing audits in Spain March 14, 2008
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Government seeks more resilient position on assessments March 13, 2008
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Irish government refuses to comment on reasons for new negotiation March 13, 2008
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Union government signs with Luxembourg and completes negotiation with Cyprus March 03, 2008
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Ramón López de Haro and Javier Montes Urdín of TP Week correspondent firm Garrigues argue that new rules will make APAs more popular March 01, 2008
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Pharmaceuticals company challenges tribunal ruling on transfer pricing February 29, 2008
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Key development of island's transfer pricing regime expected in 2008 February 29, 2008
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TP Week correspondent Machados explains why the easiest transfer pricing method is not always the best approach February 29, 2008
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Comprehensive order issued this week to implement documents law February 21, 2008
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John Nash, chief adviser to the New Zealand Inland Revenue, analyses the lessons from recent cross-border restructurings February 20, 2008
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KR Girish and Himanshu Patel, of KPMG, explain why high profile legal cases provoke a change in the law February 19, 2008
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Kishore Nair, of TP Week correspondent KPMG, reports that 72% of TNMM cases are selected for audit February 19, 2008
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TP Week correspondent backs comprehensive changes to the transfer pricing rules in pre-Budget submission February 18, 2008
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Centre for Tax Policy Administration director aims for Spring announcement February 17, 2008
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Bob Reynolds reports on new treaties finalised by Australia, Japan, Pakistan, India, Russia and Mexico February 07, 2008
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Jorge Castellon and Ramiro Bravo, of Ernst & Young, say that the lack of TP rules in Mexico can incite controversy February 07, 2008
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Andreas Köster-Böckenförde , of Jones Day in Frankfurt, explains the thinking behind recent revisions to TP law February 05, 2008
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Two TP Week surveys reveal critical importance of transfer pricing to tax directors in major industrial sectors February 01, 2008
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It will reform transfer pricing agreements, report DJ Yeo and Stefan Moller of TP Week correspondent Kim & Chang January 31, 2008
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Intra-company transactions must reported for fiscal 2007 January 24, 2008
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TP Week correspondent Machado Associados reports on a key ruling by the Brazilian tax authorities January 24, 2008
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TP specialists forecast multiple adjustments in the wake of new rules January 19, 2008
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DJ Yeo, Stefan Moller and TY Nam, of TP Week correspondent Kim & Chang outline the thinking behind Korea’s TP policy January 16, 2008
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Nick Houseman, Bill Yohana and Geoffrey Morris of PricewaterhouseCoopers Australia examine the implications of a new determination January 16, 2008
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US transfer pricing agreement - backdated to 2003 - at core of inquiry January 10, 2008
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KPMG, TP Week’s correspondent in India, comments on why TNMM is the preferred TP methodology in India. Hardev Singh reports January 09, 2008
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Rohan Phatarphekar and A Pradeep from TP Week correspondent firm KPMG in India report on two recent cases January 09, 2008
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TP Week correspondent DJ Yeo, of Kim & Chang, explains recent changes to thin capitalisation rules in Korea January 07, 2008
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UK tax authority introduces plan to cut decision times January 07, 2008
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TP Week correspondent DJ Yeo of Kim & Chang reports on the introduction of a new customs APA scheme January 03, 2008
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Pre Budget wish list calls for exemption on TP issues January 03, 2008
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John Hobster, Ernst & Young’s head of global accounts, transfer pricing talks to TP Week about the key messages from the firm’s global TP report January 03, 2008
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Deloitte in Turkey reports on key developments in Turkey’s transfer pricing policy January 03, 2008
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TP Week correspondent DJ Yeo of Kim & Chang reports on changes to Korea’s thin capitalisation rules December 27, 2007
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Deloitte in China discusses the fundamental issues for multinationals December 27, 2007
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TP Week published its list of most aggressive tax authorities list last week. The No 10 position was occupied by the HMRC December 20, 2007
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Deloitte UK analyses the HMRC’s statement of practice on advance thin capitalisation agreements. Michael Gordon-Brown and Ian Clarke report December 19, 2007
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India’s leading software trade body supports early move December 18, 2007
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TP Week correspondent Taj conducts a survey of 430 decision-makers in companies in France December 18, 2007
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Changes will broaden the base of the thin capitalisation regime December 15, 2007
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The report, Tax Risks in India, reveals fears about inconsistent rules and rulings December 14, 2007
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TP Week correspondent KPMG explains the Delhi Tax Tribunal ruling on Rolls Royce December 13, 2007
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TPWeek's snapshot guide to the key points in the Ernst & Young global transfer pricing report December 13, 2007
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Directors fear IRS will review FIN 48 workpapers December 12, 2007
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New TP rules to implement Enterprise Income Tax Law add further burdens to multinationals December 12, 2007
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John Nash, chief adviser to New Zealand’s Inland Revenue, writes exclusively on its transfer pricing policy December 11, 2007
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Politicians and lobbyists are calling for tougher transfer pricing rules – especially in the oil sector – in the Philippines. December 11, 2007
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Indian consultancies are facing a major shortage of transfer pricing specialists. December 11, 2007
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Mark Atkinson, head of transfer pricing for Deloitte UK, writing exclusively for TP Week, analysies its impact December 11, 2007
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Duff & Phelps backs new body for corporate TP professionals December 11, 2007
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UK revenue issues statement of practice and model agreement December 06, 2007
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In its first poll of senior tax directors, transfer pricing directors and advisers, TP Week reveals its definitive list December 06, 2007
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Carpet manufacturer Feltex collapses amid claims it is New Zealand’s Enron December 05, 2007
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Italy’s tough TP policy encourages more corporate deals. PwC reports December 05, 2007
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TP Week sponsor KPMG India comments on two key technical developments December 04, 2007
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Ameriprise Financial, a US financial planning company, announced yesterday that it had changed its TP methodology December 04, 2007
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TP Week sponsor KPMG reports exclusively from a meeting with the revenue body and the Big Four. KR Girish and Veena Parrikar write December 03, 2007
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Key government inquiry identifies significant weaknesses in TP policy November 29, 2007
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In the first of a series, Carol Todd of KPMG New Zealand, looks at customs valuation in her home country November 29, 2007
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Transfer pricing work is cited as a key reason for a major growth in KPMG International’s tax practice November 29, 2007
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A new agreement finalised yesterday seeks to put an end to money laundering in Fiji by international companies abusing TP rules November 29, 2007
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In a key development, the Indian tax authority reponds to pressure from business November 28, 2007
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The Federal Board of Revenue announces task force to strengthen transfer pricing rules November 28, 2007
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In an exclusive article, Todd Miller and Michael Friedman, of McMillan Binch Mendelsohn in Toronto, analyse the transfer pricing implications of the protocol November 22, 2007
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Tax authority focuses on audits and APAs, reports PwC November 22, 2007
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UN reports warns on power of mining corporations November 21, 2007
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Restructurings, intangibles, tp methods and comparability dominate OECD transfer prcing agenda November 19, 2007
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The Belgian tax authorities have reformed the state's dispute resolution approach. PwC reports. November 19, 2007
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Gianmarco Monsellato and William Finan, at TP Week sponsor Taj, argue for a policy change on intra-group interest rates November 14, 2007
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Gianmarco Monsellato and William Finan, at TP Week sponsor Taj, argue for a policy change on intra-group interest rates November 14, 2007
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Preliminary result of a study by Ernst & Young in South Africa forecasts more transfer pricing audits November 13, 2007
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The Chinese and the Korean tax authorities have signed their first bilateral advance pricing agreement (APA) November 13, 2007
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There has been considerable criticism that India fails to accord with OECD guidelines on TP policy. Hardev Singh of KPMG South India argues that it does November 08, 2007
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Bob Reynolds reports on the explosive growth in transfer pricing for intangibles in Asia Pacific November 08, 2007
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Bob Reynolds reports on a case which will have widespread implications for companies November 08, 2007
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José Luis Gonzalo, Ramón Palacín, Juan José Terraza, Carlos Gabarró, Eduardo Sánchez and Vanessa Hernández of Ernst & Young in Spain analyse the regulations take effect in 2008 November 01, 2007
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PwC analyses the regulation of transfer pricing in key European markets October 31, 2007
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The Canada Revenue Agency (CRA) recently released its 2006 annual report on Canada's advance pricing arrangement (APA) programme. The report covers the fiscal period ended March 31 2006 October 29, 2007
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The ATO is tightening its focus. PwC Australia, in this exclusive article, looks at the implications for taxpayers of its new priorities October 22, 2007
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The Taiwanese finance ministry issued new guidelines for advance pricing agreements (APAs) at the end of September. Deloitte partners Eunice Kuo and Lucia Tung report from Taipei October 22, 2007
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Transfer pricing audit costs Japanese car company in Venezuala October 22, 2007
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South Africa’s draft Revenue Laws Amendment Bill, 2007 contains a group of changes to the South African transfer pricing rules. October 19, 2007
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Substantial changes to the Russian transfer pricing regime will be debated by parliament in late November. October 18, 2007
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Mike Ahern, of PwC Poland, examines revenue authority policy on transfer pricing in Poland October 15, 2007
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By Rainer Eidemiller and Priit Lätt of Glimstedt Straus & Partners in Tallinn writing exclusively for TP Week October 12, 2007
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A more aggressive approach by China's tax authorities will be unleashed by new law. Bob Reynolds, TP Week, reports October 12, 2007
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Ed Kroft and Deborah Toaze, of McCarthy Tétrault, explain the Canadian Revenue Agency ‘s focus on TP audits October 12, 2007
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K R Girish and Veena Parrikar, of KPMG, question one solution fits all for companies seeking transfer pricing savings from shifting activities offshore October 08, 2007
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Global risk management in relation to tax and transfer pricing is becoming a top priority for both CFOs and heads of tax of multinational corporations. Michel Sijmonsbergen, Steven Carey and Carsten Schmid of Transfer Pricing Associates look at the key trends October 08, 2007
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Sergio Illanes, Miguel Zamora and Ana Paula Güitrón of Baker & McKenzie summarise the key points of the Chilean transfer pricing regime October 08, 2007
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Moisés Curiel, Carlos Linares and Eduardo Méndez of Baker & McKenzie discuss how transfer pricing policies in Mexico have changed since their introduction October 08, 2007
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The UK tax authorities are changing the way they deal with transfer pricing. So International Tax Review presents the findings of a major and timely survey of corporate taxpayers on this increasingly important subject. October 08, 2007
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By Rolf Heinrich (Germany), Andrew Hickman (UK), Pascal Luquet (France) and Steven Tseng (China) of KPMG September 28, 2007
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Jacek Bajger (Poland), Keval Doshi (India), Thomas Herr (US), Julian Hong (China) and Geoff Soh (Singapore) of KPMG discuss transfer pricing issues for emerging markets September 28, 2007
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Manuel Bouzas of Garrigues in Spain reports on new transfer pricing regulations in Spain September 27, 2007
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Gabriela Villavicencio and Armando Cabrera, of Baker & McKenzie, look how Argentina's transfer pricing rules have developed since their introduction in 1998 September 27, 2007
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Simone Dias Musa and Clarissa Machado, of Baker & McKenzie, detail the development of the transfer pricing regime in Brazil and point out its peculiarities September 27, 2007
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By Jan Martens (France), John Neighbour (UK), Damian Preshaw (Australia) and Robin Saunders (UK) of KPMG September 27, 2007
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By Gianni De Robertis (Italy), Sean Foley (US), Jaap Reyneveld (The Netherlands), Sergio Schuindt (Brazil) and Tomoko Wada (Japan) of KPMG September 27, 2007
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By Anders Bjørn (Denmark), Henrik Lund (Denmark/The Netherlands) and Steven Tseng (China) of KPMG September 27, 2007
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Stephan Rasch and Susanne Hammerschmitt of Deloitte Germany report on the transfer pricing implications of the jurisdiction's corporate tax reform law September 27, 2007
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Peter Oszkó and Annamária Kőszegi of Deloitte in Budapest report on how the tax authorities have become tougher September 27, 2007
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KR Girish and Rohit Jain, of KPMG in South India, review the impact of key transfer pricing decisions for multinational companies September 19, 2007