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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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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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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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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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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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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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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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Advisers expect President-elect Obama's administration to put changes to transfer pricing rules high on its list of priorities when he takes office November 11, 2008
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Rahul Mitra of PricewaterhouseCoopers outlines the flaws in the Indian transfer pricing regime and explains why changes need to be made to support multinational companies operating in the country November 10, 2008
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The Israeli Tax Authority (ITA) recently released the Income Tax Circular No. 3/2008 concerning transfer pricing November 05, 2008
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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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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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Russia’s weak transfer pricing regime is hindering the countries development and making the country less attractive to foreign investment, says a leading professional firm November 03, 2008
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The 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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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 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 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 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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Sweden tightens transfer pricing regulation October 28, 2008
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The new tax treaty between Spain and Colombia contains transfer pricing implications. Here Moises Curiel and Diego Gonzalez-Bendiksen of Baker & McKenzie outline the treaty elements. October 22, 2008
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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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Mary Bennett, head of the tax treaty and transfer pricing division at the OECD, has defended the discussion draft on the transfer pricing aspects of business restructuring October 22, 2008
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Daniel Rybnik of EnterPricing says that taxpayers in Argentina should be aware of the different treatment of transfer pricing policies based on variable and fixed factors October 22, 2008
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Greg Noble and Alfred Zorzi, both partners at Ernst & Young in Canada summarise what the OECD business restructuring draft will mean for Canadian taxpayers October 20, 2008
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The Ministry of Strategy and Finance announces various proposed amendments to tax laws which include provisions to provide penalty relief to taxpayers maintaining contemporaneous transfer pricing documentation. October 17, 2008
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The Korean National Tax Service recently published its 2007 APA annual report, Henry An of Samil PricewaterhouseCoopers describes some of the key elements of the report October 15, 2008
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Santino Di Libero of Gowling Lafleur Henderson believes the inclusion of mandatory arbitration in the fifth protocol to the Canada-US treaty will help the competent authority process between the two countries October 15, 2008
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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 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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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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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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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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Harlow Higinbotham and Stuart Harshbarger of NERA Economic Consulting discuss the use of credit default swaps to price intercompany loan guarantees. October 07, 2008
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John Hughes of Mayer Brown explains how taxpayers must raise the bar on transfer pricing documentation to stay inline with the new OECD discussion draft. October 06, 2008
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Christopher Steeves of Fraser Milner Casgrain analyses the recent CRA report on the mutual agreement procedure program. October 05, 2008
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Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 05, 2008
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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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KPMG has made two transfer pricing appointments in the Americas region and the US 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