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Komatsu, a Japanese construction equipment manufacturer, announced today that it is being investigated by the Japanese tax authorities over transfer pricing concerns. March 11, 2010
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A Japanese multinational announced today that the Japanese and Singapore tax authorities had negotiated a bilateral advance pricing arrangement relating to the company’s Singapore operations. March 10, 2010
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China has released a circular that drastically changes the tax rules for foreign companies deriving income through establishments in China. March 10, 2010
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The head of transfer pricing at the leading technology multinational company says that streamlining documentation processes reduced costs at the firm by as much as 50%. However, its original masterfile strategy did not meet all the company’s requirements. March 10, 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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An Indian authority has ruled that the assignment of rights and obligations is not taxable in India in the absence of a permanent establishment (PE). March 05, 2010
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TPWeek is adding to the library of documentation guides on TPWeek. This week, Belgium, Japan, Malta and Romania are new. March 03, 2010
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The Brazilian Internal Revenue Service (Brazilian IRS) has published instructions providing the currency appreciation adjustment factor to be used in the calculation of transfer prices for the calendar year 2009. March 03, 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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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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Germany has produced draft legislation that seeks to soften the transfer of function rules. The draft legislation would reform the exit charge that a company pays when it transfers its assets. February 26, 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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TPWeek is refreshing the content found in the documentation guide section of the website, be sure to take a look. February 25, 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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Advisers from Machado Associados summarise the new Brazilian transfer pricing rules and tax deductibility requirements. 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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An eagerly awaited UK transfer pricing case will not now go to court. February 24, 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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India’s finance minister has told a conference of tax officials and taxpayers that transfer pricing must play a “special role” if India is to establish itself as a leading global economy. February 22, 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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Phoenix Technologies has seen a bigger than expected revenue increase in the first three months of its financial year after settling a dispute with the Taiwan National Tax Administration (TNTA). February 17, 2010
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An Indian tax tribunal has ruled that an arm’s-length payment by a non-resident to its India permanent establishment absolves the non-resident from any additional tax liability. February 17, 2010
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Australia will introduce new tax agent services legislation on March 1 which includes information about safe harbour rules. February 17, 2010
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The Institute of Chartered Accountants of India (ICAI) is planning to help its members, especially smaller auditing firms, get information on international transfer pricing methods and systems, so they can take on larger audit assignments for companies that have overseas businesses. February 17, 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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Taxpayers in China need to urgently complete transfer pricing documentation, or face the wrath of the State Administration of Taxation. February 10, 2010
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The head of the Egyptian tax authority has announced that a circular containing transfer pricing guidelines will soon be released. February 10, 2010
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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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Stig Sollund, director general, tax law department at the Ministry of Finance in Norway answers TPWeek's questions. February 10, 2010
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Taiwan has released new assessment rules on the applicability of double taxation agreements that will affect permanent establishments in the country. February 10, 2010
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Specialist insurance company Beazley made a pre-tax profit of £100.7 million ($156 million) in 2009, up from £87.2 million in 2008, on which the company will pay just 12% income tax after it re-domiciled its holding company to Ireland. February 10, 2010
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Under pressure from countries who view Ireland as a soft touch for aggressive tax planning, Ireland has introduced new transfer pricing rules in its new Finance Bill. February 05, 2010
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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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Indonesia’s head of transfer pricing has told a seminar of tax professionals the criteria used for initiating an audit, amid increased scrutiny from the country’s tax authorities. February 03, 2010
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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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Under pressure from countries who view the country as a soft touch for aggressive tax planning, Ireland will probably introduce new transfer pricing rules tomorrow when the Finance Bill 2010 is published. The Bill will implement changes announced in the budget in December. February 03, 2010
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Taxpayers face an additional administrative burden under changes to appendix 9 of the Multiple Information Tax Return (DIM), but the acceptance of electronic filings for certain companies will speed up the process of submitting returns. February 03, 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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Eduard Sporken and Paul Kraan of KPMG Meijburg & Co explain the changes made to the European arbitration convention. February 01, 2010
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The Indian government has finally confirmed that the country’s new dispute resolution panel is not mandatory, contrary to what taxpayers were led to believe. January 29, 2010
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The Canada Revenue Agency (CRA) has increased the number of cases accepted in its advance pricing agreement (APA) programme, but the average time for closing cases has also risen. January 28, 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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Luiz Felipe Ferraz of Demarest e Almeida in Sao Paulo discusses the nuances of Brazilian tax reforms as an important reform was brought in then quickly reversed in late 2009. January 27, 2010
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China has released a tax circular that closes a loophole in the country’s thin capitalisation rules regarding the deduction of interest payments. January 27, 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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Taxpayers and advisers believe yesterday’s discussion document on controlled foreign companies reflects a genuine attempt by the UK tax authorities to respond to their concerns. January 27, 2010
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A document for discussion on the new UK CFC rules will be published by Her Majesty's Treasury and Her Majesty's Revenue and Customs on Tuesday. January 25, 2010
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How the UN transfer pricing manual should tackle documentation requirements was the subject of a spirited panel on the second day of the meeting of experts. January 21, 2010
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Providing adequate education to tax authorities in developing countries is vital when developing transfer pricing systems, according to panellists at the UN group meeting on transfer pricing. January 21, 2010
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Whether existing methods of resolving transfer pricing disputes are suitable for use in developing countries was the subject of an interesting panel at the UN expert group meeting on transfer pricing. January 21, 2010
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Speakers had much to say about the abuse of the tax rules in less sophisticated jurisdictions during a meeting of a UN transfer pricing group meeting this week. January 21, 2010
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A discussion about country by country reporting caused a heated debate at a meeting at the UN this week January 20, 2010
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Tax professionals from across Africa will meet in Cairo in February to discuss transfer pricing issues affecting the continent. January 20, 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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International Tax Review will present its fifth annual European Tax Awards at the Dorchester Hotel in London on May 18 2010 January 20, 2010
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The first panel of a group meeting on transfer pricing at the UN saw a robust argument over the merits of the formulary apportionment method against the arm’s-length principle. January 19, 2010
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Specialists at a UN meeting have stressed the importance of building transfer pricing units within the tax authorities of developing nations. January 19, 2010
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In a frank discussion at a UN meeting of experts, panellists expressed their frustrations about all the available transfer pricing methods. January 19, 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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Changes to Taiwan’s tax law mean that gains from structured notes are no longer regarded as interest income and so should be liable for withholding tax. January 18, 2010
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TPWeek will be reporting from the first UN meeting focusing on transfer pricing. January 18, 2010
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Hopes are high that more straightforward transfer pricing legislation will be enacted as part of the tax reforms expected in March this year. January 14, 2010
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The international professional services firm announced an 11.4% drop in international revenues, but a 5.3% growth in transfer pricing earnings. January 13, 2010
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The introduction of safe harbour rules in India came one step closer this week with the establishment of a committee that will finalise details of the new provision. January 13, 2010
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The Singapore government has passed a law that requires taxpayers to comply with the arm’s-length principle. January 13, 2010
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A mutual agreement procedure (MAP) for transfer pricing adjustments has been established between the Isle of Man and Australia. January 13, 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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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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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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The application of the transfer pricing rules in Brazil in relation to leasing agreements executed between related parties in Brazil and abroad is a controversial issue. January 12, 2010
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The Japanese government released an outline of its proposal for a 2010 tax reform package on December 22 2009, which is expected to be followed by the 2010 amended tax laws within a few months. January 07, 2010
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A new software product could revolutionise the often lengthy and expensive process of translating transfer pricing documentation. January 07, 2010
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The end of the year brought some good news for US taxpayers struggling with liquidity issues after the tax authorities announced they were extending for another taxable year the liberalised rules that permit a foreign subsidiary to make short-term loans to its US parent. January 07, 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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In 2010, International Tax Review is running its third annual online polls of the leading tax transactional and planning advisory firms around the world January 07, 2010
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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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Google, the internet search and software company, should expect an investigation from the UK tax authorities after it used transfer pricing to avoid corporation tax, a leading specialist has said. January 06, 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 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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The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 19 and 20 in New York. December 18, 2009
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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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The Australian government has released for public consultation draft legislation on proposed changes to the country’s thin capitalisation rules. December 18, 2009
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Brazil has unveiled legislation that contains the country’s first thin-capitalisation rules. December 18, 2009
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Taxpayers should be pleased with the news that Chile is joining the OECD as the country will benefit from a clearer set of transfer pricing rules, says a leading Chilean tax professional. December 18, 2009
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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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The Uruguayan General Tax Bureau has released a resolution that provides further details on the country’s transfer pricing regime, three months after new regulations were released. December 16, 2009
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The Dutch deputy minister of finance has proposed a new law that would make losses from permanent establishments no longer deductible from a company’s worldwide profit. December 16, 2009
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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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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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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 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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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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The release of Hong Kong’s newest practice note on transfer pricing has been widely welcomed by taxpayers, but concerns have been raised over its lack of clarity. 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 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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Recently new draft tax law provisions have been filed with the Belgian Parliament (Parl St, Kamer, 2009-2010, nr 52-2278/001) for further discussion. December 07, 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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Multinational taxpayers in Africa will have to start developing their transfer pricing policies and documentation to deal with the increasing number of countries in the region putting guidelines in place or reforming what it already has. December 02, 2009
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KPMG took the top award for transfer pricing at International Tax Review’s Asia Tax Awards in Singapore last Tuesday November 26, 2009
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Recent tax changes announced in the Netherlands budget will not affect transfer pricing, but intangibles have become a target for tax authorities November 26, 2009
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The OECD has released a revised discussion draft for a new article seven of its model tax convention, which relates to permanent establishments November 26, 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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The Australian Tax Office has hired 60 transfer pricing specialists to clamp down on abuses undertaken by large taxpayers. 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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Loss making companies, those with strange profit patterns or with a large amount of related party transactions are the key targets of audits in China, according to leading advisers. November 19, 2009
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The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 2010. November 19, 2009
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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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The introduction of safe harbour rules to India is a “double-edged sword” and the tax authorities need to be careful with how they implement them, says a report. November 19, 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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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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Companies operating in China have until December 31 to prepare comprehensive transfer pricing documentation. November 17, 2009
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The OECD has released statistics on the mutual agreement procedure (MAP) caseloads of all member countries for the period of 2006 to 2007. November 11, 2009
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Russia’s long-awaited new transfer pricing law has been submitted to the government and could be implemented in July next year. November 11, 2009
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Multinational companies need to adjust their transfer pricing systems rapidly to stave off the revenue-hungry tax authorities, says a report. November 11, 2009
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The Brazilian government is introducing a new system of reporting imports and exports relating to cross-border transactions involving services and intangibles. November 11, 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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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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Five months after the Sultanate of Oman released information on the country’s first ever set of transfer pricing rules, little is still known about what they cover. November 04, 2009
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The Chinese tax authorities have concluded their first bilateral advance pricing arrangement (BAPA) with a European country November 04, 2009
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When considering the current tax legislative agenda, what implications can we expect for transfer pricing? November 04, 2009
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In its annual report on its mutual agreement procedure (MAP) programme, the Canada Revenue Agency (CRA) notes an increase in both the number of cases brought and also the time taken to resolve the matters. November 04, 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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The Taiwan Ministry of Finance recently introduced guidelines for the determination of Taiwan source income. 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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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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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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New transfer pricing document requirements in Hungary are compliant with EU guidelines and may also simplify procedures for companies active in member states. October 29, 2009
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The number of completed advance pricing agreements (APA) has risen in Korea, according to figures released by the country’s tax authority. October 29, 2009
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The Swedish government has announced that it will enact an advance pricing agreement (APA) programme from January 1 2010 October 22, 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 commissioner of the IRS, Doug Shulman, has told board directors that they should be paying attention to their tax department's transfer pricing policies October 21, 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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China’s State Administration of Taxation (SAT) recently issued the Notice of the SAT on Certain Issues concerning the Implementation of the Articles on Royalty Payment in Tax Treaties (circular Guoshuihan [2009] number 507) October 20, 2009
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New reporting obligations in financial accounts for intercompany transactions and off-balance arrangements and the increasing use by the tax authorities of disclosures in FIN 48 reports to select taxpayers for transfer pricing audits, have complicated companies’ tax affairs in Belgium October 20, 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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The Administrative High Court of Austria has said that a precise and detailed description of the nature and market value of all intercompany services rendered to a domestic recipient is required for the fee paid for those services to be tax deductible. October 14, 2009
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The introduction of India’s new dispute resolution mechanism will reduce the amount of revenue generated through transfer pricing assessments, says a leading transfer pricing specialist October 14, 2009
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Poland has updated its transfer pricing laws with the issuance of two new decrees October 14, 2009
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Taxpayers in Africa need to be well prepared with robust transfer pricing documentation to face scrutiny of their arrangements, panellists at a recent conference said. October 14, 2009
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The high level of trade conducted through multinational companies in Canada means taxpayers there are subject to intense transfer pricing investigations. October 14, 2009
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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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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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The Turkish Revenue released guidelines on its form of mutual agreement procedure (MAP) on July 31. Advisers expect the process to become increasingly popular in the country. October 07, 2009
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Tax authorities are bulking up their dedicated transfer pricing resources and gearing up for more audits and disputes, a major international survey says. October 07, 2009
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The commissioner for Internal Revenue has lodged the IRS’ response to the petition for rehearing in the landmark Xilinx case. October 06, 2009
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The country aims to create a benchmark for coal prices which would help with pricing exports and put an end to transfer pricing abuses October 06, 2009
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In general, extensive documentation has to be prepared to demonstrate the application of the benefit test. Will the EU Joint Transfer Pricing Forum provide guidance for simplifications? October 06, 2009
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The commissioner for Internal Revenue has lodged the IRS’ response to the petition for rehearing in the landmark Xilinx case. October 06, 2009
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Decree number 392/009 amends and clarifies some of the detailed regulations established by decree number 56/009, which was issued in January 2009. October 05, 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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A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of goods purchased by Brazilian legal entities and packed or repacked locally for resale. October 01, 2009
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The number of completed mutual agreement procedures is increasing among OECD countries, new statistics have revealed October 01, 2009
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The Venezuelan tax administration (SENIAT) is continuing a transfer pricing audit campaign for fiscal years 2005 to 2008 October 01, 2009
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At International Tax Review’s fourth annual Americas Tax Awards held in New York on September 30, awards were presented for transfer pricing in 14 countries and cities. There were also a regional award each for Latin America and North America transfer pricing firm of the year. October 01, 2009
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Service transactions are the source of numerous transfer pricing disagreements between taxpayers and tax authorities, a panel of transfer pricing experts has said October 01, 2009
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The threat of taking a transfer pricing dispute to court is a good bargaining tool for taxpayers in developing countries, a panel of transfer pricing specialists has said September 29, 2009
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The economic crisis means tax authorities are conducting more audits to boost revenues. More companies are challenging adjustments, leading to a rise in controversy September 24, 2009
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Companies are changing their transfer pricing structures to deal with the global economic downturn, both to accommodate changes in the business situation and adapting to extra pressure from tax authorities. September 24, 2009
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Taxpayers and tax authorities must work together to prevent transfer pricing becoming a barrier to international trade, a leading US Treasury official has said September 24, 2009
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The future of the arm’s-length principle looks certain, as there is no viable alternative available, the head of the OECD's transfer pricing unit has said September 23, 2009
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Companies must be prepared to divulge more information for transfer pricing audits than in other similar situations, said panellists at the Global Transfer Pricing Forum September 23, 2009
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The complex procedure and uncertainty of the arbitration system in France led to some heated debate at the Global Transfer Pricing Forum September 23, 2009
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More information has been released on France’s new transfer pricing documentation requirements September 23, 2009
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The head of the OECD's transfer pricing unit told a conference in Paris today that she and her colleagues were discussing whether a project on intangibles should be part of the next work programme of the organisation's Centre for Tax Policy and Administration.
September 22, 2009
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The Chinese State Administration of Taxation (SAT) hosted an important national training session focused on the pharmaceutical industry for over 100 transfer pricing officials across the country this week September 17, 2009
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Loss-making documentation is a catch-22 situation in China. Glenn DeSouza, managing director at Transfer Pricing Management Consulting in Shanghai, which has an exclusive strategic alliance with Baker & McKenzie, explains the difficulties September 17, 2009
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President Barack Obama has revealed Michael Mundaca as his nominee for assistant secretary for tax policy, department of the Treasury. September 17, 2009
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The European Commission has proposed a revision of the code of conduct for applying the arbitration convention (AC) in a bid to strengthen the measure that acts to prevent double taxation in transfer pricing cases in the EU September 17, 2009
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India’s new dispute resolution panel is proving to be a popular choice with the country’s highest court, though the mechanism does not become effective for another two weeks September 16, 2009
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If a German affiliate of a MNE receives administrative services (for example tax, legal and accounting advice) from a foreign holding corporation what formal requirements must be met under German rules? And how do the services provide a benefit for the German company? September 16, 2009
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The OECD has released a proposed revision of several important chapters of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
September 14, 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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The lengthy process involved in arbitration matters, sometimes taking up to six years to reach a resolution needs to be changed, says a leading adviser. September 09, 2009
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International businesses need to take a more assertive, proactive approach to implementing and managing their transfer pricing policies, a report has said September 09, 2009
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The number of transfer pricing audits in Malaysia is set to increase as the country’s tax authority attempts to improve taxpayer compliance 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 US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties September 08, 2009
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Transfer pricing has never been under so much scrutiny from taxpayers and tax authorities. Profits and, consequently, tax receipts are dwindling, as the recession in the global economy has put company balance sheets and national revenues under extreme pressure September 03, 2009
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Transfer pricing has never been under so much scrutiny from taxpayers and tax authorities. Profits and, consequently, tax receipts are dwindling, as the recession in the global economy has put company balance sheets and national revenues under extreme pressure September 03, 2009
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Transfer pricing will feature strongly when International Tax Review presents its third annual Asia Tax Awards in Singapore on November 24 September 02, 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 recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing. September 01, 2009
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What does the introduction of advance pricing arrangements mean for taxpayers in India? September 01, 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
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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
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An expert panel at International Tax Review’s global TP forum in September will look at how companies deal with US cost sharing rules and compare them with similar rules in other countries. August 19, 2009
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An important concession helpful to manufacturers using mainland China contract processors has been denied. August 19, 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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What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn? August 17, 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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Xilinx has filed for a rehearing or a hearing en banc in the latest development in this historic case. August 13, 2009
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Xilinx has filed for a rehearing or a hearing en banc in the latest development in this historic case August 13, 2009
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New service regulations from the Internal Revenue Service are not expected to bring a significant effect to transfer pricing in the US. August 12, 2009
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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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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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One of the French government's senior advisers on taxation will give a keynote address at International Tax Review's Global Transfer Pricing Forum in Paris next week August 12, 2009
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On September 30, International Tax Review will present its fourth annual Americas Tax Awards in New York, celebrating among other areas, the most innovative transfer-pricing work done in North and South America between August 10 2008 and August 9 2009.
August 12, 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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My company is planning to move some operations to Brazil, what are the key transfer pricing considerations in the country? 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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Australia’s tax authorities have vowed to scrutinise taxpayers’ transfer pricing activities and thin capitalisation rules in a bid to help businesses and individuals facing genuine hardship during the economic downturn. 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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Fabia Elaine Azevedo and Cristiane Magalhães of Machado Associados discuss the transfer pricing rules on transactions between a Brazilian compnay and a non-resident related party by means of an interposed person August 05, 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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Nigerian taxpayers need to make greater efforts to comply with the country’s transfer pricing rules, a leading government official has said. July 29, 2009
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Efforts made by one UK crown dependency to enhance its network of international tax treaties have been bolstered this week by the signing of an agreement that includes transfer pricing provisions. July 29, 2009
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Businesses are paying for less external advice as they try to save money during the economic downturn. Some have turned to software to help with transfer pricing documentation. July 28, 2009
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The Australian Customs authorities have released guidance detailing how taxpayers should apply for a valuation advice relating to transfer pricing. July 23, 2009
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Transfer pricing theory has long been associated with transactions within multinational companies, but now it is being applied to the exchange of football players between English football [soccer] clubs. July 22, 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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Werner Stuffer and Jörg Hanken of PricewaterhouseCoopers discuss German business restructuring regulations and how the economic crisis affects this area of tax planning. July 21, 2009
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Governments should strengthen transfer pricing regulations and enact a general anti-avoidance rule to address cross-border-compliance risks in the recession, an IMF report has said July 21, 2009
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The milestone arrangement between China and Denmark is also the first bilateral advance pricing arrangement (BAPA) to be signed since the country’s new transfer pricing regulations were released in January 2009. July 15, 2009
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The Swedish Administrative Court of Appeal has upheld a lower court decision clarifying the determination of the arm’s-length interest rate for intercompany loans in a case involving one of the country’s largest real estate companies. July 15, 2009
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Russian tax professionals believe the country’s new transfer pricing regulations will bring in mo revenues, amid widespread transfer pricing abuses in the country’s natural resource sector. July 15, 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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Norbert Raschle, Nicolas Bonvin and Mohamed Serokh, PricewaterhouseCoopers July 14, 2009
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The UK government is asking for public opinion on new capital gains rules for groups of companies. July 08, 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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A Polish contract manufacturer for Plastic AG, a German entrepreneur, delivers the final goods directly to a customer. Now Polish SA takes over and invoices the customer. Does this trigger any German taxes? July 08, 2009
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Transfer pricing has never been under so much scrutiny from taxpayers and tax authorities. Profits and, consequently, tax receipts are dwindling, as the recession in the global economy has put company balance sheets and national revenues under extreme pressure July 07, 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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A ruling by the Pune tribunal says that the revenue authorities in India must clearly demonstrate the appropriateness of a particular method when trying to make an adjustment based on the taxpayer's method choice. Vineet Chhabra and Viswanathan Subramaniam of Deloitte explain. July 02, 2009
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We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation? July 01, 2009
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The Australian Tax Office has been given more government money to tackle aggressive schemes as the onslaught on transfer pricing uses continues in the country. July 01, 2009
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Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers. July 01, 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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Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation. June 30, 2009
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Authors of a report on tax havens and development, commissioned by the Norwegian government, believe international action is required to deal with the problem of transfer mispricing. June 30, 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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The State Administration of Taxation in China has ordered the provincial and local level tax authorities to initiate a nationally coordinated campaign of tax investigations on operators of highways. June 24, 2009
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Following a recent Indian tribunal ruling on the use of cash profit/sales, Samir Gandhi and Vineet Chhabra of Deloitte India explain the importance of profit level indicators (PLI) under the TNMM. 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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The Amsterdam Court of Appeals hands victory to the taxpayer in a transfer of goodwill dispute, limiting the taxes payable. Eduard Sporken, and Jenny Theresia of KPMG discuss the case and its implications. June 23, 2009
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TPWeek has joined Twitter, the micro-blogging and social networking site, to provide updates on the ever-changing world of transfer pricing. June 23, 2009
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The Australian Taxation Office (ATO) has released an external review of the advance pricing arrangement (APA) programme together with an initial response to the recommendations contained in the report.
June 23, 2009
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The Sultanate of Oman has finally released details for the country’s first ever set of transfer pricing rules. June 22, 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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For companies that use transfer pricing to avoid paying tax, news that country-by-country reporting is on the agenda of a meeting of G20 finance ministers in Berlin next week is bad news. June 17, 2009
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Michael D’Ascenzo, commissioner of the Australian Tax Office stressed that companies should practice good corporate governance that takes into account tax risks. 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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What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form? June 15, 2009
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The economic and technological development zone office of the Beijing Municipal State Tax Bureau (BSTB) has signed its first unilateral advanced pricing agreement (APA) after various rounds of negotiations. June 11, 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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Following the conclusion of HM Revenue and Customs first major successful transfer pricing dispute, UK taxpayers are being warned that the authorities are thirsty for more. June 10, 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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The CRA has a reputation for being aggressive. What is the best way to avoid disputes? Or handle them if they arise? June 10, 2009
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With India’s budget only three weeks away, tax professionals have come out in support of advance pricing agreements as a means of dealing with transfer pricing disputes. 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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A leading Indian business lobby group has asked the government to rethink transfer pricing rules and to create a uniform approach for information technology businesses. June 04, 2009
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What documentation do I need to prepare and file by what time for entities in Taiwan? June 04, 2009
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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, 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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Oman is set to introduce transfer pricing rules in an effort to attract further investment to the country June 03, 2009
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Taxpayers using transfer pricing to avoid paying tax could have a serious effect on Australia’s tax base, warns the country’s deputy commissioner of taxation. May 27, 2009
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My company has entities in South Korea. What are the documentation requirements for those entities? May 27, 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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The US Internal Revenue Service (IRS) is battling the UK-based pharmaceuticals company GlaxoSmithKline over a potential $1.9 billion in back taxes, interest and penalties. May 27, 2009
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In unprecedented economic times for transfer pricing, some commentators believe that existing transfer pricing models need to change to deal with the situation. May 27, 2009
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China’s State Administration of Taxation (SAT) has released guidelines, Guoshuifa [2009] number 90, concerning tax risk management practices of large enterprises. May 26, 2009
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The panellists bemoaned the documentation burden during the transfer pricing session at International Tax Review’s fourth annual Asia Tax Executives’ Forum in Singapore last week May 21, 2009
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International Tax Review announces the winners of the European Awards 2009. May 20, 2009
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The Australian government has amended the country’s thin capitalisation rules in response to concerns from the business community. May 19, 2009
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My company has entities in China. What documentation requirements do I have to fulfil, and when? May 18, 2009
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The Greek tax authorities have issued a circular that drives home the message to taxpayers that transfer pricing documentation is of extreme importance. May 18, 2009
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Michael Velten, Angie Ng and Penelope Wong move on from Transfer Pricing Associates in Asia. May 18, 2009
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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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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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Taxpayers in Thailand will be provided with more clarity and confidence for their related-party transactions as the revenue department has begun drafting long-awaited advance pricing agreement guidelines.
May 06, 2009
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The Australian Taxation Office has issued a new interpretative decision that highlights important tax issues facing foreign resident taxpayers leasing substantial equipment in Australia. May 06, 2009
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US President Barack Obama shocked the US corporate tax community this week by announcing a drastic set of plans to change the tax code. But he left transfer pricing alone, for now. May 06, 2009
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Susan George, board chair of the Transnational Institute, a worldwide fellowship of scholar activists, has slammed transfer pricing for being a hindrance to institutions such as the IMF providing financing to emerging nations. May 06, 2009
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A Grant Thornton discussion paper places transfer pricing top of the list of things companies should consider before establishing manufacturing operations to China. May 06, 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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In India, the advance ruling in the case of Canoro Resources addresses the applicability of domestic anti-avoidance provisions to transfers between partners and foreign partnerships. April 29, 2009
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A recent court ruling has determined that disputes dealing with the attribution of profits to permanent establishments in India should not be heard by the high court, as the country’s tribunals will have the final say on the matter April 29, 2009
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Car maker Chrysler is closer to a strategic alliance deal with Fiat SpA after eliminating a transfer pricing hurdle that had threatened the process. April 29, 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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As a result of the global economic downturn, governments all over the world are tightening their transfer pricing rules. Uganda's is the latest to examine these matters in more detail
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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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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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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Sometimes you just want a simple answer to a simple question. That's why the new TPDoctor section in TPWeek.com is the place for you. April 22, 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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As if filing returns under the new corporate income tax regime in China was not difficult enough, the authorities have started moving deadlines around, adding more pressure for taxpayers. April 22, 2009
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A UK charity has called on the world’s leaders to target transfer pricing abuses, amid the fear that it is depriving the world’s poorest countries of an estimated $160 billion. April 22, 2009
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Russia will adopt its long awaited revised transfer pricing legislation later this year, a government representative has said April 15, 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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The US tax authority has established a special transfer pricing council to help coordinate the IRS’ efforts in the area. Barry Shott, [LMSB deputy commissioner (international)], chairs the council and provides more details on the set up and objectives of the group in an exclusive interview with TPWeek. April 13, 2009
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The new transfer pricing regulations will bring an increase in audit activity, predicts a senior adviser April 13, 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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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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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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The Internal Revenue Service has formed a council to help it deal with transfer pricing matters effectively April 06, 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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The Danish tax authorities made transfer pricing adjustments of more than $1 billion in 2008, almost three times as much as the previous year, even though they finalised fewer cases April 01, 2009
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The Israeli tax authorities have proposed the clarification of the tax treatment of intercompany loans 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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John Brown has joined the transfer pricing practice of Ballentine Barbera, an economics consultancy, as a vice president in the New York office March 26, 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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As transfer pricing regulations have been changed each year since they were issued in December 2004, Ecuador seemed to be a less than probable candidate to start transfer pricing audits, reveals Alexis Carrera of Ernst & Young March 25, 2009
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Russia is hurriedly drafting new transfer pricing rules, five years after the reform was initially proposed March 25, 2009
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A lack of coordination between Vietnam’s two transfer pricing authorities is leading to companies failing to maintain the relevant documentation
March 25, 2009
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The UK tax authorities have amended draft legislation that will change the corporation tax rules on late-paid interest between connected companies, following initial public response to the proposal March 25, 2009
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American Apparel has told investors that its effective tax rate decreased in the fourth quarter of 2008 because of changes to its transfer pricing policy 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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International Tax Review is conducting a poll to find the 10 most admired tax directors in Europe. March 19, 2009
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New Zealand’s Inland Revenue Department (IRD) has followed through on its threat to get tough on transfer pricing and has warned businesses that they will be investigated if they fail to comply. March 18, 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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Latvia’s tax authorities are becoming more aggressive in their approach to transfer pricing and companies need to be better prepared, a tax lawyer has warned. 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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It borders on the trite to say that a company still needs to deal with its tax affairs whether it is making or losing money 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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The UK’s direct tax law was altered yesterday, as a new draft bill rewriting transfer pricing guidelines was published, though it did not deliver any substantial changes. March 04, 2009
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The Czech Republic looks set to revert to thin-capitalisation rules that existed in 2007 after a vote in the lower house of parliament on Tuesday. March 04, 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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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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An Indian automotive company has lost its appeal against the Indian transfer pricing authorities over the method used for carrying out transactions with its various entities. February 25, 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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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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The head of the organisation that represents the information technology-business process outsourcing industry in India has called on the government to introduce more generous transfer pricing rules February 19, 2009
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The New Zealand tax authority has stepped up its review of transfer pricing compliance and is set to perform more risk reviews than ever before February 19, 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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Australia and the Isle of Man have signed up to a mutual agreement procedure in transfer pricing disputes February 03, 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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Thailand has concluded its first two bilateral advance pricing agreements (APA) seven years after transfer pricing guidelines were introduced to the country. January 27, 2009
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The Indian division of Bunge, a US food company, has been ordered to pay additional taxes due to a transfer pricing-related indiscretion. The Indian income tax authority has said the company may also face a penalty for concealment of income January 27, 2009
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Her Majesty’s Revenue & Customs (HMRC) is expected to change the penalties it imposes on erroneous transfer pricing documentation from April. It is thought that the minimum penalty applied will be 10% of the total tax lost to HMRC although the total penalty will depend on the severity of the error. January 21, 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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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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The Inland Revenue Authority of Singapore (IRAS) issued transfer pricing guidelines for the first time in February 2006. In July 2008 the tax authorities opened a consultation to find out from taxpayers how the guidelines were working and if any changes were required. Chai Sui-Fun, assistant commissioner in the tax policy and international tax division of IRAS, explains the Singapore approach to transfer pricing to Ralph Cunningham of www.tpweek.com January 19, 2009
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Taxpayers, officials and practitioners can contribute to the debate on business restructuring at a conference in London on February 13, six days before the closing date for comments on the OECD's discussion draft January 15, 2009
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Slovakia has enacted an amendment that brings its transfer pricing legislation into line with the documentation requirements of the EU Joint Transfer Pricing Forum. January 14, 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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The Czech Republic government has changed the country's thin-capitalisation rules for the second time in a year. 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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On January 5 2009, the Ministry of Strategy and Finance announced it would revise the enforcement decree of the law for the coordination of international tax affairs concerning transfer pricing disclosure requirements January 09, 2009
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Goldman Sachs’ use of transfer pricing techniques among other issues, has led to investigations in numerous jurisdictions. January 07, 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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The Internal Revenue Service has issued the much anticipated regulations on cost-sharing and contract manufacturing arrangements for multinational companies. January 07, 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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Taxpayers may have to explain why they used a certain exchange rate in related-party transactions. If they cannot they could face higher tax bills, explain Jarosław Bieroński and Bartłomiej Biały of Sołtysiński Kawecki & Szlęzak December 23, 2008
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Stephanie Pantelidaki will join KPMG’s transfer pricing team in London as an associate partner December 22, 2008
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The banks' compliance burden is set to increase after an order from CBDT December 19, 2008
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Taxpayers in China will need to submit nine transfer pricing disclosure forms when they file their 2008 tax return next year December 19, 2008
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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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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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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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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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The amendment to the Polish Accounting Act of March 18 2008, part of which came into force on August 22 2008, has changed the scope of information and data to be provided in additional information to the financial statements December 15, 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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Diane Hay has left HM Revenue and Customs December 11, 2008
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The Canada Revenue Agency (CRA) recently released its annual report on advanced pricing agreements (APAs) covering the fiscal period ending March 21 2008. December 10, 2008
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A London event in February gives taxpayers the opportunity to contribute to the debate on the OECD's discussion draft on business restructuring December 10, 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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Poor countries have been warned against giving too many tax incentives and allowing transfer pricing abuses in their bid to encourage international companies to invest in their economies December 03, 2008
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HM Revenue and Customs is to introduce corporate tax legislation that amends the loan relationships rules affecting connected companies December 03, 2008
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Greece has introduced new laws to bring its transfer pricing documentation legislation more into line with OECD standards 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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Transfer pricing regulations were introduced in Columbia in 2004, Carlos Mario Lafaurie Escorce and Ricardo Suarez of PricewaterhouseCoopers explain the requirements of the laws. December 02, 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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The South African Revenue Service has said it will crack down on transfer pricing abuse amid concerns that multinationals are using the method to boost balance sheets. November 26, 2008
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Transfer pricing has long been an area of focus for the Australian Taxation Office. The ATO recently issued a taxpayer alert advising taxpayers that shifting of business losses into Australia will be under increased scrutiny 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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The OECD held a consultation on November 19 2008 with business commentators on the topics of comparability and profits under OECD transfer pricing guidelines for multinational enterprises and tax administrations November 26, 2008
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Diane Hay, chairwoman of Her Majesty’s Revenue & Customs’ transfer pricing board at HMRC would like to halve the amount of transfer pricing cases that HMRC takes up, concentrating resources on higher risk cases November 26, 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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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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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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As world markets plunge, even one of the world’s poorest nations is beginning to worry about the implications for them, and is turning to transfer pricing revenues as a means of survival November 11, 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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New Zealand’s new government sees transfer pricing as a critical piece in the country’s international tax regime, but is unlikely to tighten the current rules amid a struggling economy, a leading professional says 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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Ceteris, a global economic consulting firm that provides transfer pricing, intellectual property and valuation services has expanded into the Boston area by hiring Jill Weise and Mark Bronson as managing directors, and Kate Sullivan as a director November 04, 2008
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The Internal Revenue Service wants to tighten transfer pricing rules to stop multinational companies with US operations using them illegally to cut their tax bills
November 04, 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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Indian employers have called on the government to clarify transfer pricing rules and introduce an advance pricing agreement programme to encourage investment
November 03, 2008
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Relaxing transfer pricing regulations is one method under consideration to assist Kazakh miners in trouble 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 fact that Italy criminalises transfer pricing conflicts was a major example used to demonstrate the problems with asking tax practitioners to comply with all tax laws around the world 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 addition of Hiroaki Furuya to Gardere’s international tax and transfer pricing (ITTP) practice strengthens an already robust team October 28, 2008
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An experienced Japanese professional has joined the Texas firm October 28, 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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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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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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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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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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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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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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The Ministry of Mines and Energy in Namibia wants to amend a section of the existing Minerals Act to impose a royalty on all minerals mined or discovered during prospecting operations October 14, 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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Forest Laboratories, a US pharmaceutical company, used transfer pricing methods to channel more than $2 billion through its Irish operation in the last financial year October 14, 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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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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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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Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 05, 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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KPMG has made two transfer pricing appointments in the Americas region and the US 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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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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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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One of the key players in the IRS-Glaxo transfer pricing dispute that ended in September 2006 has joined The Brattle Group, a firm of economic, finance and regulation consultants that advises companies, law firms and governments around the world September 25, 2008
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Joanna Faith reports on the eighth Global Transfer Pricing Forum which drew together top names for two days in Rome 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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Transfer Pricing Associates (TPA) Global has opened six new offices in Argentina, Brazil, Mexico, Switzerland and the US.
September 19, 2008
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The OECD is expected to release a draft discussion on transfer pricing issues in business restructuring next week. September 17, 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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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 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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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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Ramazan BİÇER, senior transfer pricing specialist in the Transfer Prising Division of the Turkish Revenue Administration, describes the regime for transfer pricing documentation in Turkey September 04, 2008
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Malaysian taxpayers will soon be able to apply for advance pricing arrangements September 04, 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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Ramazan BİÇER, senior state revenue specialist of the Turkish Revenue Administration, discusses an amendment to transfer pricing law in Turkey that deals with the loss of tax revenue to the National Treasury August 28, 2008
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Alexis Carrera Reyes of Ernst & Young reports on how reform to new thin-capitalisation rules can help taxpayers in Ecuador August 28, 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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In less than a month, leading transfer pricing personalities from all over the world will be gathering in Rome for International Tax Review's 8th Global Transfer Pricing Forum. 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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Jarosław Bieroński and Bartłomiej Biały, of Sołtysiński Kawecki & Szlęzak, believe taxpayers should prepare contemporaneous transfer pricing documentation as the tax authorities may ask for them August 26, 2008
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Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador August 21, 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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Glenn DeSouza, managing director, TP Management Consulting, Shanghai, and Benjamin Cheong, intellectual property group, Baker & McKenzie, Hong Kong believe you have to consider the tax implications when seeking to protect your intellectual property in China August 13, 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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A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP Week.com lists more than 350 cases.
August 07, 2008
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Transfer pricing comes out as the key issue for tax executives in nearly all surveys that International Tax Review conducts 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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The Australian Taxation Office has issued a discussion paper on thin capitalisation to its National Tax Liaison Group Transfer Pricing subgroup July 24, 2008
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The OECD’s transfer pricing guidelines for application to separate but associated enterprises should apply in the attribution of profits to permanent establishments (PEs), said a report by the organisation July 24, 2008
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Gustavo Haddad and Bruno Carramaschi,of Lefosse Advogados in cooperation with Linklaters, explain what Brazil’s authorities have done to update rules on dealing with tax havens July 17, 2008
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Courtney Fowler of PricewaterhouseCoopers says Kazakhstan needs to change its policy, for example, regarding international agreements and international disclosure, if it is to make it into the WTO July 17, 2008
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Tax professionals and others have until the end of this year to comment on a draft of a new version of article 7 of the OECD’s Model Tax Convention and related commentary changes July 10, 2008
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Romania and Bulgaria have joined the European Commission's Arbitration Convention. The two EU member states acceded to the process on July 1. July 09, 2008
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The EU Joint Transfer Pricing Forum (EUTPF) was set up to develop regional transfer pricing policy in Europe hand in hand with industry July 09, 2008
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Advisers believe Australia's tax treaties should not give the authorities an unlimited period in which to launch transfer pricing audits July 02, 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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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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TP Week correspondent Machado Associados reports on safe harbour rules in the Brazilian transfer pricing regime June 19, 2008
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PricewaterhouseCoopers Canada outlines the main points in the Glaxo Canada ruling June 19, 2008
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SUNAT issues guidance on filing dates for 2007 tax returns June 19, 2008
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Medical devices business faces higher tax bill over Irish subsidiary June 12, 2008
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Government also introduces fees for advance pricing agreements June 12, 2008
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New regulations implement 2006 Income Tax law June 12, 2008
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Transfer pricing at the heart of alleged state losses of $63 million 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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CRA audit focuses on Gildan’s offshore sales and marketing subsidiaries June 02, 2008
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Tax authority says it will concentrate on intangibles and restructuring June 02, 2008
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In the second in our series on double tax treaties, Gustavo López-Ameri of Deloitte & Touche in Lima reports on Peru's transfer pricing policy May 30, 2008
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Tax authority announces new structure to change filing requirements May 30, 2008
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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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Tax authority issues advance notice of key changes May 29, 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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Hardev Singh and Saurabh Dhanuka, of KPMG, TP Week’s correspondent in India, give practical advice on dealing with India’s revenue authorities May 22, 2008
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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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TP Week’s Brazil correspondent Machados Associados comments on the debate over the basket method May 21, 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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Former Cadbury Schweppes and Andersen tax man is specialist in APAs
May 19, 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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Responses to consultation paper support wide use of transactional profits methodologies 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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Canadian electronic manufacturing systems business hits tax authority trouble May 08, 2008
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Multinationals in Russia face more onerous documents regulation
May 08, 2008
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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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Finance ministry to issue circular letter to industry and tax profession April 30, 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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Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year 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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Swedish Tax Agency proposal covers bilateral and multilateral APAs April 22, 2008
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Takashimaya hits transfer pricing troubles over Singapore business April 21, 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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Felipe González Martín, of TP Week correspondent firm Garrigues, reports on a critical development for transfer pricing in Spain April 16, 2008
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Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta April 15, 2008
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Spanish National Court sets standard for intra-group services evidence April 14, 2008
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Big-four firm announces key appointments in the US and Latin America April 11, 2008
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Indian government is more focused on general election, say local commentators April 10, 2008
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New departure from IRS programme is senior transfer pricing figure 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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Jonathan Lubick, of Ballentine Barbera, and Henriette Fuchs, of Tadmor Attorneys, in Tel Aviv, describe the documentation evironment in Israel April 09, 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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Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process April 07, 2008
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Kai Hielscher and Steven Wrappe join in transfer pricing practices in Munich and US from Deloitte 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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Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit April 06, 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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Presidential candidate pledges to eliminate cross-border tax advantages April 03, 2008
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TP Week correspondent Machado Associados reports on the process for transfer pricing audits in Brazil April 03, 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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H Ching Tan and Douglas Fone, of Transfer Pricing Associates, examine the transfer pricing issues in funding for Chinese enterprises March 25, 2008
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Kenya, Tanzania, Uganda, Rwandi and Burundi seek year end implementation March 25, 2008
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Practice appoints Luis Castillo for Spain and Latin America March 25, 2008
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Top level transfer pricing executive John Breen joins DC law firm March 24, 2008
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TP Week correspondent Machado Associados
outlines the environment for transfer pricing documentation in Brazil March 22, 2008
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Former Big Four and IRS intangibles expert takes up new role in London March 20, 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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Dunja Hitrec, of Ernst & Young in Zagreb, looks at the Croatian tax authority’s approach to transfer pricing auditing March 15, 2008
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Lucijan Klemencic, of Ernst & Young in Ljubljana, reports on the regime for transfer pricing audits in Slovenia March 15, 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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Hedvig Solyomvari, of Ernst & Young, reports on the climate for transfer pricing audits in Hungary March 14, 2008
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TP Week correspondent Jacques Van Rhyn, of PricewaterhouseCoopers, explains the environment for transfer pricing audits in South Africa March 14, 2008
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Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008
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Eran Shif, of Ernst & Young in Israel, describes the approach of the Israeli tax authorities to transfer pricing audits 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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Speciality international pharmaceutical company concludes advance pricing agreement for 2006-2010 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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John Nash, chief adviser to the NZ Inland Revenue Department, describes the experience since the guidelines were introduced 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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Mirror reporting by foreign enterprises mandatory February 15, 2008
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Artur Klesk, head of transfer pricing at Accreo Taxand, a leading Polish TP commentator, discusses the fortunes of the APA initiative February 14, 2008
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Spanish government's implementation regulations for documentation issued in draft format February 14, 2008
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Pharmaceuticals company faces court battles with revenue authorities February 14, 2008
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Mario Ortega Calle, of TP Week correspondent Garrigues, explains how the regulation of intra-group expenses has changed February 13, 2008
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Caribbean state confirms OECD principles in law. Brian Hanney reports on a move to documents rules February 07, 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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Hardev Singh and Saurabh Dhanuka, of TP Week correspondent KPMG, report on the tribunal’s analysis of transfer pricing approaches February 06, 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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The most comprehensive guide to regulation of documentation worldwide January 31, 2008
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Government announces TP is among key reasons for inquiry January 31, 2008
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Intangibles can be assessed by transactional profit as well as traditional transaction methods January 25, 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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Intra-company transactions must reported for fiscal 2007 January 24, 2008
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Australian Taxation Office wants to stop flight of revenues January 24, 2008
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Company agrees to $5 million bond to allow export of latest consignment January 24, 2008
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Transfer Pricing Associates announces Washington DC office after London launch January 19, 2008
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TP specialists forecast multiple adjustments in the wake of new rules January 19, 2008
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China's State Administration of Taxation reports revenue up 45% January 17, 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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Ray Dybala, 30 year veteran in tax, joins law firm January 16, 2008
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Company also gains $1.4 million from APA with Internal Revenue Service and Revenue & Customs January 14, 2008
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Bottled water company clashes with Pacific nation revenue authority over $3 million a week in exports January 13, 2008
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Financial adviser recruits leading TP specialist as managing director January 10, 2008
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US transfer pricing agreement - backdated to 2003 - at core of inquiry January 10, 2008
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Glenn DeSouza, managing director, TP Week correspondent Transfer Pricing Management Consulting (TPMC), an allied firm of Baker & McKenzie January 09, 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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Transfer pricing specialist Andrew Kim is one of six associates promoted to partner by law firm Fenwick & West 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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New TP rules to implement Enterprise Income Tax Law add further burdens to multinationals December 12, 2007
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Directors fear IRS will review FIN 48 workpapers 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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Team leader Teshome is poached from Grant Thornton, team from KPMG 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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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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UK revenue issues statement of practice and model agreement 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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E&Y TP senior partner Okawara to lead new team December 04, 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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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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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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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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The Federal Board of Revenue announces task force to strengthen transfer pricing rules November 28, 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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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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East African government seeks to avoid transfer pricing on oil imports November 21, 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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Chiltern's head of transfer pricing rejects BDO for new firm 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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PricewaterhouseCoopers comments on the transfer pricing policy of the German tax authorities November 12, 2007
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John Neighbour runs a team of 80 UK-based transfer pricing specialists for KPMG. He was formerly head of transfer pricing at the OECD November 08, 2007
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Income Tax Department appeals decision on captive 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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Bob Reynolds reports on the explosive growth in transfer pricing for intangibles in Asia Pacific November 08, 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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Three of the 57 new partners admitted by PwC in China and Hong Kong are transfer pricing specialists. They are among 11 new tax partners. November 04, 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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In the second part of a TP Week interview with the HMRC's Roy Warden, he points to fewer inquiries but the possibility of more litigation November 01, 2007
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The Israeli tax authorities have published a form for the reporting of cross-border transactions. November 01, 2007
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The Income Tax department says Indian companies can enjoy same benefits as US companies 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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James Gatley, of KPMG in Toronto analyses the recent Hallmark Cards ruling October 30, 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 number of mutual agreement procedures (MAP) involving an advance pricing agreement (APA) in Japan has increased by 600% in the last decade. October 29, 2007
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Transfer Pricing Solutions, a UK-based boutique transfer pricing consultancy, has recruited Peter Male from Ernst & Young. October 24, 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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Rosa Maria Soares, transfer pricing partner at Deloitte in Lisbon, describes plans for advance pricing agreements in Portugal 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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Pan-European Group begins focus on transfer pricing implications of business reorganisations October 17, 2007
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The government has announced a series of key changes to transfer pricing rules which take effect on January 1 2008. October 17, 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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Global law firm forms alliance with Transfer Pricing Management Consulting October 15, 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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Hardev Singh, senior manager in the transfer pricing department at KPMG India, looks at the efforts of income tax and customs departments to achieve consistency from multinationals. October 09, 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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The Brazilian tax authorities introduced the data generator programme of the International Audit Systems - PGD-AUDIN. October 08, 2007
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Alvarez & Marsal Taxand, an affiliate of Alvarez & Marsal (A&M), announced it has recruited two experienced transfer pricing economists. Mike Murphy has joined as a managing director and national practice leader and Laurie Dicker as a managing director and economist. They are based in Washington DC. October 02, 2007
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Sponsored Americas piece by Alan Granwell and Eric Ryan of DLA Piper US September 28, 2007
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US investment bank extends its financial advisory practice September 27, 2007
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HMRC seeks the view of big business on its transfer pricing recommendations September 27, 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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Bowen to run US TP practice September 27, 2007
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Australian bank could be scrutinised over growth in business in Valetta September 27, 2007
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Sponsored India report from Rohan Phatarphekar and Hardev Singh of KPMG India September 27, 2007
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Craig McAree is poached from Grant Thornton to launch new team September 26, 2007