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Three new dispute resolution panels have been set up in Mumbai, New Delhi and Hyderabad to ease the burden of dealing with taxpayers’ applications for resolutions. February 26, 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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A tax dispute between global pharmaceutical firm, AstraZeneca, and HM Revenues and Customs (HMRC) has been deferred until April 2010, with the outcome of the case expected to have an impact on multinationals and their transfer pricing regimes.
January 20, 2009
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Stuart Edwards of PricewaterhouseCoopers, Australia, believes courts will favour traditional transactional transfer pricing methods rather than bottom line profits methods in the wake of the landmark Roche decision. July 30, 2008
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An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
June 30, 2010
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The Australian Taxation Office (ATO) has lodged an appeal to the Full Federal Court of Australia against the recent transfer pricing decision in the SNF case. September 01, 2010
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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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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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On December 4 2009, the long awaited decision in General Electric Capital Canada Inc v The Queen was released by Canada's Tax Court. December 09, 2009
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The company reported making a loss of A$107.9 million ($94 million) after being hit with a tax adjustment reportedly relating to intercompany transactions. July 12, 2010
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Hasnain Shroff, A Pradeep and Vinita Chakrabarti of KPMG India discuss taxpayers' relief over finding out that the use of the new Indian dispute resolution mechanism is optional. February 02, 2010
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Ricardo Escobar, the chief of the Chilean tax authority (Servicio de Impuestos Internos or SII), says the SII has detected “certain abusive behaviours from the Chilean taxpayers”. December 16, 2009
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Two companies that took on the tax authorities in the US and UK over transfer pricing issues, and achieved positive results, have now reported higher than expected earnings. May 04, 2010
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An Indian court has outlined the three criteria that taxpayers must satisfy to constitute a fixed place permanent establishment. June 09, 2010
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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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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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Multinationals in Russia face more onerous documents regulation
May 08, 2008
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In a landmark decision, the US Tax Court has addressed the fundamental issues in the valuation of cost-sharing buy-ins and slammed the approach of the Internal Revenue Service (IRS) to the case. December 16, 2009
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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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On January 4 2010, the Crown deposited its notice of appeal with the Federal Court of Appeal to the judgment of the Tax Court of Canada issued on December 4 2009 in the case of General Electric Capital Canada Inc v The Queen. January 07, 2010
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A case that has just been decided in the Czech Supreme Administrative Court (SAC) provides an important discussion on transfer pricing methodology in disputes with the tax authorities in the context of the Czech tax law. February 23, 2010
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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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The Delhi bench of the Income-tax Appellate Tribunal held that interest-free loans advanced by Indian companies to their foreign affiliates do not comply with the arm’s-length standard. February 10, 2010
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The Delhi bench of the Income-tax Appellate Tribunal has upheld the exclusion of non-operating incomes like interest, dividends and income from share trading while determining profit margin under the transactional net margin method (TNMM). June 08, 2010
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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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The European Court of Justice (ECJ) has upheld a discrepancy in Belgium’s transfer pricing rules, even though it represents a restriction on the EU freedom of establishment. February 03, 2010
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Stefaan De Baets, First Attaché of Finances at the Belgian Finance Ministry, along with representatives from the country’s competent authority and the transfer pricing audit teams reveal how ECJ rulings may alter transfer pricing in the country. May 12, 2010
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The conclusion of a bilateral advance pricing agreement (APA) between the US and the Netherlands will allow FEI, a scientific instruments company, to release large valuation allowance and tax reserves from its accounts for the second quarter of 2010. June 28, 2010
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Shiraj Keshvani served until March this year as the chief economist for Canada Revenue Agency’s (CRA’s) competent authority services division and was the national coordinator for the advance pricing arrangement (APA) programme. August 13, 2010
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TP Week correspondent KPMG explains the thinking behind the recent Foster’s case in before the Authority for Advance Rulings in India May 29, 2008
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The GE Capital case has left market commentators encouraged but in doubt about what the judgement really means for the arm’s-length principle in Canada. December 16, 2009
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Pharmaceuticals company could face massive tax bill
June 12, 2008
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PricewaterhouseCoopers Canada outlines the main points in the Glaxo Canada ruling June 19, 2008
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GlaxoSmithKline Canada has won its appeal against a 2008 judgment by the Tax Court of Canada that it paid a Swiss related party too much money for the active ingredient in Zantac. August 02, 2010
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Hasnain Shroff and Vinita Chakrabarti of KPMG in India look at the Global Vantedge case. January 27, 2010
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The test claimants in the UK thin-capitalisation group litigation against HM Revenue & Customs have won their challenge in the High Court in London that the rules infringed the freedom of establishment article of the European Treaty. November 19, 2009
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An expert panel at International Tax Review’s Global TP Forum in September will look at the best way to handle tax controversy and alternatives to litigation. August 12, 2009
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Samir Gandhi, Manisha Gupta and Viswanathan Subramaniam of Deloitte India explain the importance of maintaining appropriate documentation to evidence that the transaction price has been computed in good faith and with due diligence. October 29, 2009
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One of the world’s largest technology companies is challenging the Indian Directorate of Revenue Intelligence’s biggest claim to date. May 11, 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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Information and guidelines on India’s new alternate dispute resolution mechanism has been pushed back once again, amid growing uncertainty from the country’s tax professionals. October 29, 2009
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An Indian court has ruled that Coca-Cola India failed to apply transfer pricing rules following an agreement to offer advisory services to a related party. January 07, 2009
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Samir Gandhi and Manisha Gupta of Deloitte India explain the importance of recent controversy for taxpayers dealing with issues involving section 40A of the 1961 Income Tax Act. November 04, 2009
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The special bench of Chandigarh Income Tax Appellate Tribunal has restated the critical importance of conducting a detailed FAR analysis. February 04, 2010
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An Indian tax tribunal has ordered a Belgian drug company to rethink its transfer pricing methods for transactions with its Indian subsidiary, despite referring the case back to the transfer pricing officer. April 08, 2009
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A recent Indian tribunal ruling has emphasised the importance of using comparable data for the purpose of benchmarking controlled transactions. January 06, 2010
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The Mumbai Income Tax Appellate Tribunal has ruled that when determining the arm’s-length price of an international transaction, transfer pricing officers (TPO) must apply transfer pricing methods in accordance with the manner in which they are prescribed in the country’s transfer pricing rules. February 25, 2010
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India’s new dispute resolution panels (DRP) will continually adapt to a changing tax environment and greatly improve taxpayer litigation consistency, say two of the country’s leading advisers. April 13, 2010
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Hasnain Shroff and Poonam Ghelani in India look at the important VVF Limited case. February 16, 2010
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Citrix Systems, a provider of IT solutions, has announced it has settled with the IRS in the range of $12 million to $15 million over disputes about transfer pricing and intellectual property transfers. July 06, 2010
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Inter-company services charges again under the transfer pricing spotlight May 27, 2008
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The Danish tax authorities have collected DKK 15 billion ($2.8 billion) from transfer pricing audits of 32 multinational companies. April 15, 2010
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Medical devices business faces higher tax bill over Irish subsidiary June 12, 2008
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In a recent ruling in the case of Gharda Chemicals Limited, interesting questions were raised before the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT), the second appellate and the last fact finding authority in Indian judiciary. January 12, 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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Bankrupt multinational telecommunications equipment manufacturer, Nortel Networks Corporation, has announced that it has entered into a final Canadian Funding and Settlement Agreement that includes the resolution of a transfer pricing dispute with the Internal Revenue Service in the US. January 06, 2010
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The Norwegian tax authorities recently won its overhead costs case against Enterprise Oil Norway (EO) in the Norwegian courts, because EO could not provide sufficient documentation to show that it had received the services that it had paid for. May 28, 2010
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A decision by the Massachusetts Appellate Tax Board (ATB) has sent a warning to state tax auditors not to overreach in assessments related to inter-company pricing of services and products provided between companies and their out-of-state affiliates.
May 14, 2009
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The Federal Board of Revenue (FBR) in Pakistan believes pharmaceutical companies have used transfer pricing to evade Rp500 million ($5.8 million) in taxes. June 30, 2010
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The dispute resolution panel at International Tax Review's Global Transfer Pricing Forum will focus on planning transfer pricing policies to avoid disputes, achieving settlements and using advanced pricing agreements (APAs).
September 01, 2010
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Deal reduces the technology company’s tax bill for the fiscal years 2000 to 2006 by $5.2 million. November 17, 2009
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Polish taxpayers have been sent a strong warning after the country’s tax authorities confirmed that they will focus their 2010 audit work on transfer pricing and its associated issues. April 07, 2010
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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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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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The introduction of new transfer pricing documentation rules has led to taxpayers facing more frequent and detailed audits of their activities than ever before. August 12, 2009
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Software corporation goes to court next month in the US
May 22, 2008
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A service provider has become one of the first companies to take a transfer pricing dispute to the Supreme Administrative Court. July 21, 2010
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CRA loses case to gain access to details on financial transactions June 19, 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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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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Taxpayers should view litigation as the last resort for resolving transfer pricing disputes, senior tax executives and practitioners told a conference in London. March 12, 2010
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Paul Flignor, Alan Granwell and Eric Ryan of DLA Piper discuss the landmark Veritas decision and the implications for taxpayers December 18, 2009
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Hasnain Shroff, Vinita Chakrabarti and Akash Arora discuss the Nimbus Communications Ltd Vs ACIT, Mumbai (ITA No.2361 (Mum.) of 2007) case and its implications for transfer pricing. July 20, 2010
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Multinationals are paying significantly more tax to resolve transfer pricing disputes. With litigation a costly and time consuming option for both the taxpayer and the tax authority, thoughts are turning to alternative dispute mechanisms. March 24, 2010
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The UK Pensions Regulator’s decision to issue its second ever Financial Support Direction against 25 companies in the Nortel Group in Canada, the US, Europe and Africa is because, in part, of an investigation into the telecommunications group’s transfer pricing arrangements. August 04, 2010
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Chemical company Innospec Limited has signed a £3.9 million ($6.5 million) agreement with HMRC in settlement of transfer pricing disagreements. January 18, 2010
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In a surprise move the US Court of Appeals for the ninth circuit has withdrawn the opinion and dissent filed on May 27 2009. January 13, 2010
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The company was given leave to file a reply in answer to the commissioner for Internal Revenue’s response to the petition for a rehearing. October 14, 2009
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In a series of amicus briefs filed with the US Court of Appeals for the Ninth Circuit, several powerful groups have expressed their support for Xilinx in the latest phase of its battle with the Internal Revenue Service. August 25, 2009