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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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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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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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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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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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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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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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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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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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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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Hasnain Shroff and Poonam Ghelani in India look at the important VVF Limited case. February 16, 2010
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Inter-company services charges again under the transfer pricing spotlight May 27, 2008
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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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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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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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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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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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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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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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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