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The IRS has affirmed its commitment to the much-criticised investor model approach to the taxation of cost sharing arrangements (CSAs).
December 21, 2011
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Norway’s Supreme Court has ruled that Dell Products, a Norwegian commissionaire company, does not constitute a sales agency permanent establishment (PE) in Norway. December 05, 2011
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The Indian government has said guarantee fees, paid by Indian companies in the acquisition of foreign assets, fall into the income tax net because they are a cost to the company. November 02, 2011
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Micro-blogging site Twitter has announced its European headquarters will be based in Ireland, joining a number of other hi-tech companies, to make use of its 12.5% corporate tax rate and beneficial transfer pricing regime. October 04, 2011
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The transfer pricing spotlight has now fallen on IT companies in India, with claims that foreign firms are booking less profit than their domestic rivals. September 14, 2011
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The OECD’s report on how some companies create losses through aggressive tax planning is not revolutionary, by their own admission, but taxpayers say governments are missing a trick. September 02, 2011
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Vodafone is one of four companies Christian Aid is trying to convince to support country-by-country reporting with its FTSE4 campaign. August 10, 2011
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Microsoft has taken advantage of transfer pricing to lower its effective tax rate in the US to just over half the statutory tax rate, according to its Form 10-K filing with the Securities Exchange Commission (SEC). August 03, 2011
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A panel at the National Association of Business Economics Transfer Pricing Symposium, near Washington this week, explored the implications of pre-existing intellectual property (IP) in the IRS’s transfer pricing cases against software companies Xilinx and Veritas. July 27, 2011
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The Joint Committee on Taxation, the group consisting of members of both houses of the US Congress, laid out its plan for tackling the definition of transfer pricing intangibles in its June 14 report on the Obama administration’s proposed budget for fiscal year 2012.
July 06, 2011
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In the latest transfer pricing case to emerge in Canada, the taxpayer has won a judgment from the Tax Court over reassessments made by the Canada Revenue Agency (CRA) worth about C$2.7 million ($2.7 million) even though the taxpayers’ transactions were found to contravene the arm’s-length principle. May 25, 2011
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Computer company IBM has lost a two-year dispute with the Australian Tax Office (ATO) over royalties paid to its American parent. April 20, 2011
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The Supreme Court of Canada met last week to hear the Canada Revenue Agency's (CRA) appeal and GlaxoSmithKline’s (GSK) response in a case about whether the taxpayer paid too much for active pharmaceutical ingredients (API) from a Swiss associated enterprise. January 17, 2012
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The Supreme Court of Canada has named the date for the GlaxoSmithKline hearing, which will finalise the long-running transfer pricing dispute. January 03, 2012
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Boston Scientific, a US medical technology company, has filed a petition to the US Tax Court in a fight against a $581 million transfer pricing adjustment from the IRS. December 16, 2011
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Takeda Pharmaceuticals has announced that its mutual agreement procedure (MAP) with the National Tax Agency in Japan did not result in an agreement with the US. November 22, 2011
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The Tax Court of Canada has begun hearing another transfer pricing case. November 01, 2011
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GlaxoSmithKline (GSK) has filed its case facts with the Supreme Court of Canada refuting arguments made by the Crown in this precedent-setting transfer pricing case, involving the price of the active ingredient used to make the drug sold under the brand name Zantac. September 19, 2011
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Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC). April 06, 2011
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The Canada Revenue Agency has been given leave to appeal the GlaxoSmithKline case to the Supreme Court. A cross-appeal from the taxpayer was also accepted. March 25, 2011
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The Mumbai Income Tax Tribunal (ITAT) has sent back the file of Teva India, dealing with pharmaceuticals, to the transfer pricing officer (TPO) to reassess whether Vimta Labs, a contract research and testing organisation with abnormally high profit, is comparable to a contract R&D provider. March 22, 2011
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Rohan Phatarphekar and Manish Bafna, of KPMG, dissect the Mumbai ITAT ruling in the case of Serdia Pharmaceuticals and explain why APIs can constitute a comparable uncontrolled price (CUP) for the import of drugs when the patent has expired. January 19, 2011
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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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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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Western Union has announced that it has reached an agreement with the US IRS over the transfer pricing aspects of its restructuring of international operations in 2003. December 19, 2011
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The backbone of transfer pricing for most multinational enterprises is the OECD Transfer Pricing Guidelines. However, financial services transfer pricing (FSTP) is unique. October 24, 2011
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A panel of advisers, taxpayers and government officials, at International Tax Review’s 11th Global Transfer Pricing Forum last week, discussed the challenges involved in dealing with financial transactions. September 23, 2011
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Thin capitalisation rules were introduced in Brazil by Executive Measure 472/09, approved by Law 12249/10, and regulated by the Federal Revenue Service Normative Instruction 1154/11 (IN RFB 1154). July 26, 2011
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US Senator Carl Levin at a July 12 press conference presented a revised version of his 2009 Stop Tax Haven Abuse Act. July 13, 2011
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Chinese tax authorities are giving financial institutions a deadline of only one to two weeks, rather than 20 days, to submit transfer pricing documentation for the 2008 and 2009 financial years.
June 13, 2011
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Foreign banks with permanent establishments (PE) in the UK may have difficulty in providing an accurate calculation for the bank levy, which was introduced in January this year. February 25, 2011
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Gordon Hands and John Hollas of CUFTanalytics provide a new perspective and transfer pricing methodology for this relatively common but often misunderstood intra-group financial transaction. September 28, 2010
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In his 2010 budget speech, Alistair Darling, the chancellor of the exchequer, said that £2 billion ($3 billion) has been raised by the UK bank payroll tax. Advisers believe that this may have implications for financial institutions’ transfer pricing arrangements. March 31, 2010
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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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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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Pepsi Foods’ stay of application with the Indian legal system over a demand of Rs1.04 billion ($21 million) has been disposed by the Income Tax Appellate Tribunal (ITAT) but an appeal date has been set. February 21, 2012
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An estimated $110 billion disappeared because of transfer mispricing on the import of crude oil in the EU and US between 2000 and 2010, a recent report from Publish What You Pay (PWYP) Norway said. February 17, 2012
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While Vodafone secured a historic victory in the Supreme Court of India last week, there is still the issue of an Rs8,500 crore ($1.7 billion) transfer pricing order from the Income Tax Department. January 24, 2012
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The European Tax Awards are expanding this year, with the inclusion of South Africa. January 18, 2012
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In the most recent stage of the GE Canada transfer pricing dispute, the taxpayer’s attempt to strike the Canada Revenue Authority’s (CRA) pleadings has failed. January 05, 2012
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The decision on intercompany debt funding has been made by the New Zealand High Court in Alesco New Zealand Ltd v CIR. January 03, 2012
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December 21, 2011
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The OECD is considering the Canadian Alberta Printed Circuits transfer pricing dispute as a case study in its intangibles project, according to the company’s expert witness. December 13, 2011
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While all taxpayers deal with intellectual property (IP), and the evaluation issues surrounding it for taxation purposes, some taxpayers place more value on it than others. Paul Morton, the head of tax for publishing house, Reed Elsevier, explains the practical day-to-day problems surrounding IP, when operating on a global scale. December 08, 2011
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Gazprom, one of the world’s biggest energy producers, is rumoured to have applied for an advance pricing agreement (APA) with the Russian tax authorities, after requests to be excluded from the new transfer pricing regulations. November 04, 2011
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The Indian transfer pricing authorities have no right to question the commercial wisdom of the taxpayer in incurring expenditure for business conduct, the Mumbai Income Tax Appellate Tribunal has ruled. October 05, 2011
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Australia’s proposed Minerals Resource Rent Tax (MRRT) poses transfer pricing problems for taxpayers with all but the simplest transactions, adding to the uncertainty surrounding the tax. October 05, 2011
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Gagan Kumar of Archer & Angel explains the intricacies of the Diageo India case.
October 04, 2011
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A New Zealand court case involving debt finance is creating waves because it seems the Inland Revenue Department (IRD) is contradicting its own guidelines. September 16, 2011
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The Vietnamese tax authorities have released a mid-year statement indicating that reported revenue loss has decreased by $100 million. September 14, 2011
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Forget player transfers, it’s transfer pricing that could put Manchester City Football Club under the microscope of football’s governing body, UEFA. August 31, 2011
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Practitioners have said the decision to move responsibility for the US advance pricing agreement programme (APA) and mutual agreement procedure (MAP) from the Office of Chief Counsel to the IRS commissioner has as much to do with the faith in the ability of Mike Danilack, deputy commissioner (international) of the Large and Mid-Size Business Division (LB&I), as it has to do with efficiency.
August 30, 2011
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The Australian Taxation Office (ATO) is targeting foreign companies that shift profits offshore to reduce their local tax liability. The application of transfer pricing rules will be reviewed.
July 13, 2011
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Deloitte's new partner is based outside London. July 13, 2011
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The Italian tax authorities have released guidelines on accessing the transfer pricing penalty protection regime. The transfer pricing rules themselves remain unaffected, but the guidelines clarify the procedure for application to obtain penalty protection.
July 11, 2011
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In a new ruling, the Australian Tax Office (ATO) has set out how it expects business structuring for multinational enterprises to be documented for transfer pricing purposes. July 06, 2011
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July 06, 2011
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The Australian Tax Office (ATO) will not appeal the Full Federal Court decision on comparables, which ruled in favour of the taxpayer, SNF, as the 28-day leave for the Commissioner to seek appeal has now passed. July 01, 2011
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Countries losing money from multinationals’ transfer pricing are, more often than not, lacking the ability to implement the arm’s-length principle effectively, one of Africa’s leading tax officials has said .
July 01, 2011
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Five African governments will convene in South Africa next month to discuss SABMiller's transfer pricing strategies in the continent. May 06, 2011
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Taxpayers can no longer use companies with segmental results, or those with a comparatively low turnover, as a comparable for benchmarking purposes under transfer pricing provisions in India. May 04, 2011