-
The Portuguese tax authority has turned its transfer pricing focus to residual pricing methods, meaning companies should stop using them if they want to save money. February 02, 2012
-
Experts are applying a new technique to avoid the application of the Brazilian resale price minus method. February 01, 2012
-
Historically, Sweden has been seen as something of a tax haven, at least in terms of the availability of interest deductions. However, David Perrone and Anna Karlgård, of KMPG, explain why this will soon change. January 30, 2012
-
International Tax Review has compiled a special free pdf report on Vodafone’s Indian Supreme Court victory. View the ruling, read what industry had to say, and uncover what this decision means for your business. January 30, 2012
-
The way tax administrations select transfer pricing cases for audit varies dramatically in sophistication across the world. Learning their tactics is vital for taxpayers looking to avoid the scrutiny of revenue-hungry officials. January 30, 2012
-
Angola is undergoing major reforms to its tax system, including the establishment of a transfer pricing regime, set to be introduced in March. January 24, 2012
-
Whether the euro breaks-up or whether the EU can hold it together, taxpayers should be aware of the implications a break-up would have on their transfer pricing arrangements. January 24, 2012
-
While Vodafone secured a historic victory in the Supreme Court of India last week, there is still the issue of an Rs8,500 crore ($1.7 billion) transfer pricing order from the Income Tax Department. January 24, 2012
-
Tax directors have said that transfer pricing advisers are out of touch when it comes to market demand. January 19, 2012
-
The European Tax Awards are expanding this year, with the inclusion of South Africa. January 18, 2012
-
Taxpayers can expect the US Internal Revenue Service (IRS) to announce its new head of the advance pricing agreement programme by the end of January. January 18, 2012
-
The Supreme Court of Canada met last week to hear the Canada Revenue Agency's (CRA) appeal and GlaxoSmithKline’s (GSK) response in a case about whether the taxpayer paid too much for active pharmaceutical ingredients (API) from a Swiss associated enterprise. January 17, 2012
-
As the dollar and the euro increase the value of the real, the Brazilian government has introduced measures to stem any further appreciation. January 17, 2012
-
President Obama and the House Ways and Means Committee chairman, David Camp, offered competing international tax system reforms at the end of 2011. January 16, 2012
-
The new head of the OECD's tax treaty, transfer pricing and financial transactions division has been named. January 11, 2012
-
The Netherlands has introduced a deduction for capital expenditure associated with R&D, effective January 1 2012, which has implications for transfer pricing. January 10, 2012
-
Russian companies with significant foreign capital and high debt to equity ratios, are at risk of attack by the tax authorities following a recent Supreme Arbitration Court (SAC) ruling. January 10, 2012
-
The Hong Kong Inland Revenue Department (IRD) will launch an advance pricing agreement (APA) programme in April. January 09, 2012
-
The outline for Japanese tax reform proposals was released on December 26 2011 with changes to intercompany loan regulations. January 06, 2012
-
A recent ruling by the Tax Tribunal of Korea said companies that make transfer pricing adjustments after reporting importation to customs will not be refunded. January 05, 2012
-
In the most recent stage of the GE Canada transfer pricing dispute, the taxpayer’s attempt to strike the Canada Revenue Authority’s (CRA) pleadings has failed. January 05, 2012
-
The decision on intercompany debt funding has been made by the New Zealand High Court in Alesco New Zealand Ltd v CIR. January 03, 2012
-
China has underlined its determination to strengthen its anti-avoidance rules by concluding the country’s first thin capitalisation audit. January 03, 2012
-
The Supreme Court of Canada has named the date for the GlaxoSmithKline hearing, which will finalise the long-running transfer pricing dispute. January 03, 2012
-
The IRS has affirmed its commitment to the much-criticised investor model approach to the taxation of cost sharing arrangements (CSAs).
December 21, 2011
-
HMRC in the UK has released for the first time extensive statistics about its transfer pricing enquiries, advance pricing agreements (APAs), and mutual agreement procedure (MAP). December 20, 2011
-
Throughout the year, Brazil has been at the centre for conflicting decisions issued by the administrative and judicial courts on transfer pricing matters. December 20, 2011
-
Western Union has announced that it has reached an agreement with the US IRS over the transfer pricing aspects of its restructuring of international operations in 2003. December 19, 2011
-
By Danny Beeton, Murray Clayson and Michael Blau of Freshfields Bruckhaus Deringer December 16, 2011
-
By Danny Beeton, Murray Clayson and Michael Blau of Freshfields Bruckhaus Deringer December 16, 2011
-
The jobs of both Caroline Silberztein, the OECD's head of the transfer pricing unit in the tax treaty, transfer pricing and financial transactions division, and Mary Bennett, the head of the division itself, were advertised by the OECD in May.
December 16, 2011
-
The Australian Tax Office (ATO) has lost its appeal against the taxpayer, SNF, at the Full Federal Court in a transfer pricing case concerning comparables and method application.
December 16, 2011
-
After years of delay, the Russian parliament has finally passed the new transfer pricing rules, though there have been significant amendments.
December 16, 2011
-
President Obama’s tax reform proposals for the US include transfer pricing provisions which promise to reduce the nation’s deficit by $24 billion over 10 years.
December 16, 2011
-
Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC).
December 16, 2011
-
Boston Scientific, a US medical technology company, has filed a petition to the US Tax Court in a fight against a $581 million transfer pricing adjustment from the IRS. December 16, 2011
-
The OECD has released mutual agreement programme (MAP) statistics for 2010. Canada, Germany and Poland tell TPWeek what these stats mean for them. December 14, 2011
-
The Indonesian government has introduced a number of changes to its transfer pricing regime that will affect the way taxpayers apply the arm’s-length principle on related party transactions. December 13, 2011
-
The OECD is considering the Canadian Alberta Printed Circuits transfer pricing dispute as a case study in its intangibles project, according to the company’s expert witness. December 13, 2011
-
Michelle Levac, the chairwoman of the OECD’s Working Party No 6 on the transfer pricing aspects of intangibles, spoke exclusively to TPWeek about the project’s progress and her concerns for its development. December 08, 2011
-
While all taxpayers deal with intellectual property (IP), and the evaluation issues surrounding it for taxation purposes, some taxpayers place more value on it than others. Paul Morton, the head of tax for publishing house, Reed Elsevier, explains the practical day-to-day problems surrounding IP, when operating on a global scale. December 08, 2011
-
The UK Treasury today released draft legislation on the creation of a patent box for intellectual property (IP) management. December 06, 2011
-
Norway’s Supreme Court has ruled that Dell Products, a Norwegian commissionaire company, does not constitute a sales agency permanent establishment (PE) in Norway. December 05, 2011
-
The US and Canadian arbitration provisions were implemented on December 15 2010 but, since then, it is rumoured that only two cases have gone through the process. December 01, 2011
-
New regulations brought in by the Venezuelan government to control costs and prices could force multinationals, operating in the country, to make transfer pricing adjustments. December 01, 2011
-
International Tax Review, in association with Economic Laws Practice, invites you to join a free webinar: Transfer pricing issues surrounding marketing intangibles – with special insights from an Indian perspective. December 01, 2011
-
The Mexican Revenue Authority has confirmed it intends to release more transfer pricing guidance for taxpayers in 2012, but a specific date has not been confirmed. November 29, 2011
-
The UN Subcommittee on Dispute Resolution has released a report identifying three options for how arbitration can be used as an additional mechanism for mutual agreement procedures. November 29, 2011
-
Petra Foods, an Indonesian taxpayer, has referred to previous payments for a transfer pricing adjustment as recoverable in its third-quarter 2011 statement, meaning it expects to win its dispute with the Indonesian Tax Office. November 24, 2011
-
In transfer pricing, the main problem for practitioners is to choose which method they will use to calculate an arm’s-length price. They must also decide which profit level indicator (PLI) they will select to support their argument. November 23, 2011
-
Takeda Pharmaceuticals has announced that its mutual agreement procedure (MAP) with the National Tax Agency in Japan did not result in an agreement with the US. November 22, 2011
-
Taxpayers in Poland are not taking advantage of the country’s advance pricing agreement (APA) regime because of the length of time it takes to complete an application, statistics reveal. November 21, 2011
-
Intangible property is an important income generator for many multinational enterprises (MNE), so the OECD consultation with business on the transfer pricing aspects of intangibles was well attended. But, not all taxpayers were in agreement on the issues. November 16, 2011
-
Ghana is moving towards implementing a transfer pricing regime with the help of a German development agency. November 16, 2011
-
The EU Joint Transfer Pricing Forum (JTPF) will focus on cost sharing agreements (CCA) in service arrangements. Intangible assets, however, will be left out of the discussions. November 15, 2011
-
This year’s final figure of Rs44,500 crore ($8.9 billion) for transfer pricing adjustments in India is more than double last year’s total. November 14, 2011
-
The business advisory body to the OECD (BIAC) is asking for more involvement in the OECD’s drafting of guidelines for the transfer pricing aspects of intangible assets. Read a full transcript of the BIAC tax and fiscal policy committee’s plea. November 10, 2011
-
This week’s OECD meeting with business representatives to discuss the transfer pricing aspects of intangibles began with a summary of the project so far. November 08, 2011
-
Before delegates left the OECD’s transfer pricing aspects of intangibles meeting on Monday night, they were asked a number of questions for overnight deliberation by Joseph Andrus, the new head of transfer pricing at the OECD. November 08, 2011
-
The OECD’s Working Party No 6 meeting on the transfer pricing aspects of intangibles brought the aspect of synergies into discussion. November 08, 2011
-
The concept of goodwill in the transfer pricing of intangible assets was discussed by delegates at the OECD’s Working Party No 6 meeting last week. November 08, 2011
-
The second refusal of the UK Supreme Court to refer the Thin Cap GLO to the ECJ has been described as “inconsistent” and “wrong” and will end up costing taxpayers a lot of money if they decide to persist with the litigation. November 07, 2011
-
Danny Beeton and Rupert Macey-Dare, of Freshfields Bruckhaus Deringer’s London office, analyse the technicalities of the latest Canadian transfer pricing dispute. November 04, 2011
-
Gazprom, one of the world’s biggest energy producers, is rumoured to have applied for an advance pricing agreement (APA) with the Russian tax authorities, after requests to be excluded from the new transfer pricing regulations. November 04, 2011
-
Australia has released a consultation paper aiming to bring its transfer pricing regulations more in-line with international best practice, following the Revenue’s defeat in the SNF case earlier this year. November 03, 2011
-
The commissioner for large business at the IRS has explained the benefits of the recent transfer pricing reshuffle within the IRS. November 02, 2011
-
The Indian government has said guarantee fees, paid by Indian companies in the acquisition of foreign assets, fall into the income tax net because they are a cost to the company. November 02, 2011
-
The Tax Court of Canada has begun hearing another transfer pricing case. November 01, 2011
-
The UN subcommittee drafting the practical manual on transfer pricing for developing countries said the document will be constantly updated and so, initially, it will not attempt to fully address the issue of intangibles but instead will wait for the results of the OECD project on the subject. October 31, 2011
-
Pascal Saint-Amans will replace Jeffrey Owens as head of tax policy and administration at the OECD in February. In an exclusive interview, he told TPWeek that transfer pricing will be one of his core priorities. October 27, 2011
-
Delegates at the UN’s Committee of Experts on International Cooperation in Tax Matters are voicing their concerns about the wording of the UN model double taxation convention relating to transfer pricing. October 27, 2011
-
A Canadian taxpayer has made an advance pricing agreement (APA) request to the Mexican tax authorities and has made an unusual amount of information public. October 27, 2011
-
The UN Committee of Experts on International Cooperation in Tax Matters has come to an agitated approval of the commentary on article 9 of the OECD’s transfer pricing guidelines. October 27, 2011
-
The UN Committee of Experts on International Cooperation in Tax Matters is in progress this week in Geneva, Switzerland. October 26, 2011
-
Norway does not have a formal advance pricing agreement (APA) programme but some taxpayers are achieving advance agreements with the authorities and the process is getting quicker. A pilot programme is now in place. October 25, 2011
-
The backbone of transfer pricing for most multinational enterprises is the OECD Transfer Pricing Guidelines. However, financial services transfer pricing (FSTP) is unique. October 24, 2011
-
The adoption of the Tax Code by the Ukrainian Parliament at the end of 2010 has become a milestone event for the Ukrainian business community, including a substantial revision of the transfer pricing regulations. Yuliya Nogovitsyna and Anna Vitko, of KPMG, provide an overview of the new regulations and their impact on taxpayers operating in the Ukraine. October 24, 2011
-
Sam Maruca, the new director of transfer pricing at the Internal Revenue Service (IRS) in the US, is now two months into his specially created role and tells TPWeek that his main focus is enforcement. October 21, 2011
-
The Australian Taxation Office (ATO) has released proposals, for consultation, for a new international dealings schedule (IDS), to replace the schedule 25a and thin capitalisation forms. October 19, 2011
-
The OECD has proposed changes to article 5 of the Model Tax Convention regarding permanent establishment (PE) and is inviting public comment. October 19, 2011
-
The Japanese and Australian competent authorities held a seminar last week to discuss a more streamlined approach to bilateral advance pricing agreements (APA) between the two countries. October 19, 2011
-
The recent ActionAid report that accused 98% of the UK’s FTSE 100 of using tax havens to harm developing countries is not news to HM Revenue & Customs and has been denounced as misleading. October 19, 2011
-
By Kathrine Kimball, Aaron Bone, and Minjung Kim of Charles River Associates October 17, 2011
-
Google is under audit in the US following reports it uses transfer pricing to reduce its overseas effective tax rate down to just 2.4%. October 17, 2011
-
One year on, the Norwegian tax authorities annual report shows transfer pricing is still a key focus area. Amrit Paul Singh and Hans-Martin Jørgensen of Deloitte explain why. October 14, 2011
-
A recent decision on importation from the Brazilian administrative courts reopened a transfer pricing question that appeared to be definitively settled in favour of the Brazilian Federal Revenue (RFB). Gil Mendes, and Daniel Perin, of Ernst & Young analyse how a taxpayer became the first to prevail over the authorities on the issue. October 12, 2011
-
The Task Force on Financial Integrity & Economic Development’s annual conference in Paris discussed the problems of trade mispricing, or transfer pricing abuse, and looked at how to combat it. October 12, 2011
-
US Customs and Border Protection (CBP) is inviting public comment on its decision to reconsider its approach to post-import value adjustments. October 12, 2011
-
HM Revenue & Customs has updated the guidance in its international manual for taxpayers, including changes to the transfer pricing provisions. October 12, 2011
-
Cristiane Magalhães and Angélica Santos of Machado Associados, Brazil, comment on the main aspects and difficulties of the adjustments to business conditions allowed by the Brazilian transfer pricing legislation in part two of a two-part investigation. October 11, 2011
-
Joseph Andrus, the new head of the OECD’s transfer pricing unit, has negotiated high profile transfer pricing cases for some of the biggest companies in the world but he was no match for French immigration, arriving one week late to his post. October 11, 2011
-
The US Council for International Business (USCIB) has told the OECD that it opposes the definition of intangibles as “something of value”. October 05, 2011
-
The Indian transfer pricing authorities have no right to question the commercial wisdom of the taxpayer in incurring expenditure for business conduct, the Mumbai Income Tax Appellate Tribunal has ruled. October 05, 2011
-
Australia’s proposed Minerals Resource Rent Tax (MRRT) poses transfer pricing problems for taxpayers with all but the simplest transactions, adding to the uncertainty surrounding the tax. October 05, 2011
-
Gagan Kumar of Archer & Angel explains the intricacies of the Diageo India case.
October 04, 2011
-
Micro-blogging site Twitter has announced its European headquarters will be based in Ireland, joining a number of other hi-tech companies, to make use of its 12.5% corporate tax rate and beneficial transfer pricing regime. October 04, 2011
-
China’s State Administration of Taxation has clarified a number of issues relating to the administration of foreign companies that are controlled by Chinese investors. October 03, 2011
-
One of the few transfer pricing cases to go to trial in the US in the last decade has won an award from International Tax Review for Symantec, the taxpayer at the centre of the litigation.
September 28, 2011
-
A panel at the Global Transfer Pricing Forum in London last week took a look at financial valuation methods for intangibles and found that they interacted surprisingly well with transfer pricing methods. September 28, 2011
-
China’s State Administration of Taxation (SAT) has released information on how taxpayers should prepare and complete contemporaneous transfer pricing documentation for the coming year. September 28, 2011
-
European tax officials gave delegates at the Global Transfer Pricing Forum last week an insight into the issues they look for when assessing taxpayers. September 28, 2011
-
Taxpayers in the emerging BRIC economies need to be aware that face-to-face interaction with officials will reduce the length of transfer pricing disputes, says panel. September 27, 2011
-
President Obama’s tax reform proposals for the US include transfer pricing provisions which promise to reduce the nation’s deficit by $24 billion over 10 years. September 27, 2011
-
A panel of advisers, taxpayers and government officials, at International Tax Review’s 11th Global Transfer Pricing Forum last week, discussed the challenges involved in dealing with financial transactions. September 23, 2011
-
Krister Andersson, chairman of the tax policy group at Business Europe, opened the second day of International Tax Review’s 11th annual Transfer Pricing Forum with an overview of the changes to the tax landscape and how this is affecting the business community. September 21, 2011
-
A panel of experts at International Tax Review’s 11th annual Transfer Pricing Forum said there is a lot of positivity around the advance pricing agreement (APA) programme in the UK, and complimented the UK tax authorities for their commitment to the programme. September 21, 2011
-
The European transfer pricing panel, on day one of International Tax Review’s Global Transfer Pricing forum yesterday, was boosted by revenue officials from the Netherlands, Spain and France. September 21, 2011
-
Giving his keynote address to International Tax Review's 11th Global Transfer Pricing Forum, Dave Hartnett, permanent secretary for tax at HM Revenue & Customs (HMRC), drew on lessons learned from the OECD's Forum on Tax Administration, which looks at practical issues of transfer pricing for tax administrations. September 20, 2011
-
Taxpayers need to be aware that transfer pricing joint audits are just around the corner and should begin preparing for them now, says a panel of leading experts. September 20, 2011
-
Representatives from various factions of the OECD discussed the projects on intangibles and the administrative aspects of transfer pricing at International Tax Review's 11th Global Transfer Pricing Forum. September 20, 2011
-
GlaxoSmithKline (GSK) has filed its case facts with the Supreme Court of Canada refuting arguments made by the Crown in this precedent-setting transfer pricing case, involving the price of the active ingredient used to make the drug sold under the brand name Zantac. September 19, 2011
-
A New Zealand court case involving debt finance is creating waves because it seems the Inland Revenue Department (IRD) is contradicting its own guidelines. September 16, 2011
-
By Qisheng Yu, Amy Cai and Wing Siu, PwC China September 15, 2011
-
The Vietnamese tax authorities have released a mid-year statement indicating that reported revenue loss has decreased by $100 million. September 14, 2011
-
The transfer pricing spotlight has now fallen on IT companies in India, with claims that foreign firms are booking less profit than their domestic rivals. September 14, 2011
-
Who will come out on top at International Tax Review’s Americas Tax Awards next month?
September 14, 2011
-
When it comes to transfer pricing, the world traditionally turns to the OECD and its Transfer Pricing Guidelines. But, as more countries attempt to implement transfer pricing guidelines and legislation, the demand for simplification, especially from developing countries, increases. September 13, 2011
-
The District Court of the Hague has ruled, in a transfer pricing dispute, that the profits of an Irish reinsurance company are considered taxable income for its Dutch shareholder. Eduard Sporken and Dirk Brouwers of KPMG Meijburg & Co discuss the case and its implications. September 12, 2011
-
Paul Smith and Wendy Nicholls of Grant Thornton UK welcome the new patent box proposals but believe the take-up will be small because of the restriction to patents and the highly complicated calculation of patent box profits. September 12, 2011
-
The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday. September 12, 2011
-
Who will come out on top at International Tax Review’s Americas Tax Awards this month?
September 07, 2011
-
RN Dash, the Indian director general of income tax, spoke about the country’s efforts in transfer pricing today at International Tax Review’s India Tax Forum in Delhi.
September 07, 2011
-
The transfer pricing panel at International Tax Review’s India Tax Forum covered a range of issues affecting Indian taxpayers, with practical advice and experiences given.
September 07, 2011
-
A US policy group said US companies avoided approximately $60 billion in corporate tax in 2010 through various means, including transfer pricing, and have added 44 substantial new subsidiaries in tax havens. September 07, 2011
-
The Baltics region has witnessed increased transfer pricing development in recent years but practitioners say more guidance is needed. September 07, 2011
-
The OECD’s report on how some companies create losses through aggressive tax planning is not revolutionary, by their own admission, but taxpayers say governments are missing a trick. September 02, 2011
-
An embedded intangible is an element of another category of transaction, according to Rob Plunkett of Deloitte’s Washington office. August 31, 2011
-
Forget player transfers, it’s transfer pricing that could put Manchester City Football Club under the microscope of football’s governing body, UEFA. August 31, 2011
-
Caroline Silberztein’s replacement as head of the OECD’s Transfer Pricing unit has been named as Joseph Andrus. August 30, 2011
-
Practitioners have said the decision to move responsibility for the US advance pricing agreement programme (APA) and mutual agreement procedure (MAP) from the Office of Chief Counsel to the IRS commissioner has as much to do with the faith in the ability of Mike Danilack, deputy commissioner (international) of the Large and Mid-Size Business Division (LB&I), as it has to do with efficiency.
August 30, 2011
-
An industry body has exclusively revealed to TPWeek that the Vietnamese government will introduce an advance pricing agreement (APA) programme in its tax code. August 25, 2011
-
An international research centre will launch in the Netherlands next month to study and analyse transfer pricing issues to assist multinationals (MNE) and governments to deal more effectively with the increasing complexity of transfer pricing. August 24, 2011
-
Caroline Silberztein is a big name in transfer pricing circles. As head of the OECD’s transfer pricing unit she has helped shape the way the world approaches and applies transfer pricing guidelines for the past 10 years. August 23, 2011
-
Advisers in Estonia have said the new transfer pricing guidelines, introduced by the Tax and Customs Board, are not comprehensive enough for taxpayers. August 17, 2011
-
The case of Symantec Software Solutions Pvt Ltd, heard before the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), has implications for the application of transfer pricing provisions, which continue to differ from global best practice.
August 17, 2011
-
Brazil’s transfer pricing rules are predominantly outlined in Law 9430, as amended, and by the Federal Revenue Service’s Normative Instruction (NI) 243. August 15, 2011
-
Brazil’s transfer pricing rules are predominantly outlined in Law 9430, as amended, and by the Federal Revenue Service’s Normative Instruction (NI) 243. August 12, 2011
-
The economic recession has a lot to answer for. But, it is also the reason why transfer pricing has become a pressing issue for taxpayers everywhere. August 11, 2011
-
Weeks after Turkey agreed its first unilateral advanced pricing agreement (APA) on July 15 and more than three years after taxpayers were eligible to apply for them, interest in APAs remains thin on the ground. August 10, 2011
-
Vodafone is one of four companies Christian Aid is trying to convince to support country-by-country reporting with its FTSE4 campaign. August 10, 2011
-
Discrepancies between the OECD guidelines and Russia’s new transfer pricing legislation, which the president signed into law last month, could cause problems for international groups.
August 10, 2011
-
By Carlos Mario Lafaurie Escorce of PwC Colombia August 10, 2011
-
Next year will herald a widescale period of change for tax in India. It will force tax directors from domestic and international companies to completely reconsider their strategies and to seek efficiencies at all levels of their company's tax affairs.
August 10, 2011
-
Mary Bennett, the head of OECD’s tax treaty and transfer pricing division, said communication is a barrier to the Centre for Tax Policy and Administration improving its reputation, but steps are being taken to change this. August 09, 2011
-
Microsoft has taken advantage of transfer pricing to lower its effective tax rate in the US to just over half the statutory tax rate, according to its Form 10-K filing with the Securities Exchange Commission (SEC). August 03, 2011
-
In a speech to business economists, Sam Maruca, who has taken on the new role as head of transfer pricing in the IRS, described his plans for the new role and the transfer pricing strategies the IRS will undertake. August 03, 2011
-
A torrent of criticism has followed the EU’s release of a transfer pricing report on developing countries. August 03, 2011
-
By Brad Rolph of Charles River Associates July 29, 2011
-
The IRS is moving its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes, to bring them together under the Large Business & International (LB&I) Division’s international operation. July 29, 2011
-
The lack of clarity in part of a new transfer pricing form issued by Malaysia’s tax authorities will create some difficulties and pitfalls for taxpayers. July 27, 2011
-
A panel at the National Association of Business Economics Transfer Pricing Symposium, near Washington this week, explored the implications of pre-existing intellectual property (IP) in the IRS’s transfer pricing cases against software companies Xilinx and Veritas. July 27, 2011
-
The Delhi Tribunal, in the case of CRM Services, a call centre provider, has passed a relevant ruling for captive IT enabled or business process outsourcing (BPO) service providers. July 27, 2011
-
Thin capitalisation rules were introduced in Brazil by Executive Measure 472/09, approved by Law 12249/10, and regulated by the Federal Revenue Service Normative Instruction 1154/11 (IN RFB 1154). July 26, 2011
-
By Peerapat Poshyanonda and Alisa Arechawapongsawat of PwC Thailand July 26, 2011
-
By SM Thanneermalai and Anushia Soosaipillai of PwC Malaysia July 25, 2011
-
By Sergio Franco and María José Santos of PwC July 25, 2011
-
The African Tax Administration Forum’s (ATAF) first general assembly in Mauritius next week will focus on illicit financial flows, tax evasion and tax avoidance. July 21, 2011
-
The Dominican Republic’s tax authority, Direccion General de Impuestos Internos (DGII), is implementing new documentation requirements on transfer pricing, effective fiscal year 2011. July 20, 2011
-
After years of delay, the Russian parliament has finally passed the new transfer pricing rules, though there have been significant amendments. July 20, 2011
-
The economic recession has a lot to answer for. But, it is also the reason why transfer pricing has become a pressing issue for taxpayers everywhere. July 20, 2011
-
Bangladesh’s National Board of Revenue intends to check irregular transfers of funds in a bid to reduce the estimated $35 billion revenue loss attributed to transfer pricing. July 20, 2011
-
Japan’s transfer pricing legislation was revised on June 30 2011 to introduce the most appropriate method rule, rather than the hierarchy system, which is now abolished. July 20, 2011
-
The Ho Chi Minh City Tax Department in Vietnam has promised to investigate global companies who claim to make consistent losses in the country. July 20, 2011
-
Turkey hopes to move on to negotiating bilateral advance pricing agreements after the signing of its first unilateral APA last week. July 20, 2011
-
The OECD received 22 different contributions from advisers concerning its June 10 report “Multi-country Analysis of Existing Transfer Pricing Simplification Measures”. July 13, 2011
-
The Australian Taxation Office (ATO) is targeting foreign companies that shift profits offshore to reduce their local tax liability. The application of transfer pricing rules will be reviewed.
July 13, 2011
-
Taxpayers in China transferring equity interests in Chinese companies are being advised to conduct appraisals to determine the fair market value of the transferred interest. July 13, 2011
-
A report released this week by the Oxford University Centre for Business Taxation (CBT), commissioned by the OECD Informal Task Force on Tax and Development, has called for new transparency measures in disclosing tax payments and profits for multinational companies.
July 13, 2011
-
US Senator Carl Levin at a July 12 press conference presented a revised version of his 2009 Stop Tax Haven Abuse Act. July 13, 2011
-
The Italian tax authorities have released guidelines on accessing the transfer pricing penalty protection regime. The transfer pricing rules themselves remain unaffected, but the guidelines clarify the procedure for application to obtain penalty protection.
July 11, 2011
-
Taxpayers need to examine and evaluate the comparable studies they plan to use in China after a transfer pricing adjustment grabbed the headlines. July 07, 2011
-
In a new ruling, the Australian Tax Office (ATO) has set out how it expects business structuring for multinational enterprises to be documented for transfer pricing purposes. July 06, 2011
-
Taxpayers in France should be aware that they still need to justify their choice of comparables, even if the authorities have limited scope to make adjustments in this area, explain Jean-Luc Trucchi and Edouard Berthelot of Taj
July 06, 2011
-
International Tax Review will present its sixth annual Americas Awards at the Waldorf-Astoria Hotel in New York on Tuesday September 27. Now is your chance to enter. July 06, 2011
-
The Joint Committee on Taxation, the group consisting of members of both houses of the US Congress, laid out its plan for tackling the definition of transfer pricing intangibles in its June 14 report on the Obama administration’s proposed budget for fiscal year 2012.
July 06, 2011
-
July 06, 2011
-
The Australian Tax Office (ATO) will not appeal the Full Federal Court decision on comparables, which ruled in favour of the taxpayer, SNF, as the 28-day leave for the Commissioner to seek appeal has now passed. July 01, 2011
-
Countries losing money from multinationals’ transfer pricing are, more often than not, lacking the ability to implement the arm’s-length principle effectively, one of Africa’s leading tax officials has said .
July 01, 2011
-
Colombian taxpayers that are required to prepare a Transfer Pricing Study no longer have to file an additional return form (form 1525), which details comparables information in the study. June 30, 2011
-
The US State of New Jersey says it is not bound by advance pricing agreements (APA) with the IRS. June 29, 2011
-
Mary Bennett and Caroline Silberztein, both part of the OECD’s Centre for Tax Policy and Administration (CTPA), are to join the Baker & McKenzie network. June 28, 2011
-
Stefaan De Baets, a senior OECD representative, said the up-coming Working Party 6 meeting in November, to discuss the transfer pricing aspects of intangibles, would focus on valuation methods. June 27, 2011
-
By Cecilia Lee, Colin Farrell, Rhett Liu, David Smith and Deborah Li of PwC Hong Kong.
June 24, 2011
-
Denmark has signed a third bilateral advance pricing agreement (BAPA) with China. It is the only European country to have signed even one. June 24, 2011
-
By Barbara Dooley and Gavan Ryle of PwC, Dublin. June 23, 2011
-
The US is one of six countries highlighted in an OECD survey as having measures to simplify transfer pricing that are specifically geared toward low value-added services. June 23, 2011
-
The proposed Mineral Resource Rent Tax (MRRT) will require the use of domestic transfer pricing, an exposure draft revealed. June 22, 2011
-
Argentina has released a resolution stating the taxpayer must submit a new tax return detailing transactions with foreign related companies in low tax jurisdictions. June 22, 2011
-
India and the OECD have announced plans for a three-year partnership to strengthen cooperation and provide greater opportunities for structured dialogue and information sharing. June 22, 2011
-
Taxpayers are finding it more difficult to comply with the growing amount of transfer pricing documentation requirements. June 22, 2011
-
Uganda has announced it will introduce transfer pricing regulations from next month. June 20, 2011
-
Both the OECD and the UN are working to reform international tax rules, one representing the developed world; the other the developing nations. But, who will come out on top?
June 20, 2011
-
By Nicole Fung and Michael Nixon, PwC Singapore June 20, 2011
-
In the run-up to the general election in Denmark, which must be held by November 12, multinational entities (MNEs) have been the focus of political debate over the amount of taxation they pay. Transfer pricing in particular has proved controversial.
June 17, 2011
-
The OECD has released a multi-country analysis of existing transfer pricing simplification measures.
June 15, 2011
-
The Informal Meeting on the Practical Transfer Pricing Issues for Developing Countries, which was convened in New York last week, discussed the UN’s draft manual which will offer guidance on the practicality of adapting OECD guidelines to developing countries. June 15, 2011
-
Pranab Mukherjee, India’s finance minister, said transfer pricing is robbing developing nations of scarce natural resources.
June 15, 2011
-
By Mike Ahern, Piotr Wiewiorka, and Przemyslaw Orwat, of PwC Poland June 14, 2011
-
Chinese tax authorities are giving financial institutions a deadline of only one to two weeks, rather than 20 days, to submit transfer pricing documentation for the 2008 and 2009 financial years.
June 13, 2011
-
Transfer pricing abuse has sparked amendments to Kenyan tax law in the country’s recent budget. June 10, 2011
-
A Czech Supreme Administrative Court ruling has set groundbreaking rules for the burden of proof in transfer pricing cases. Libor Frýzek and René Kulínský, of Ernst & Young, discuss. June 10, 2011
-
The Australian Tax Office (ATO) has lost its appeal against the taxpayer, SNF, at the Full Federal Court in a transfer pricing case concerning comparables and method application. June 08, 2011
-
A French company has lost its appeal at the Nantes Administrative Court over the burden of proof and the assignment of affiliated company liabilities in transfer pricing. June 08, 2011
-
The Chilean Ministry of the Treasury is expected to present a Transfer Pricing Bill to the National Congress soon. June 08, 2011
-
In a binding private ruling, the South African Revenue Service (SARS) has concluded that a non-resident company, whose effective management is not in South Africa, does not constitute a permanent establishment (PE). June 08, 2011
-
A new draft law in Latvia, proposing changes to the transfer pricing system, was announced by the State Secretaries last month. June 08, 2011
-
By Henrik Hansen, Evgenia Veter and Alexey Sobchuk of Ernst & Young, Russia June 03, 2011
-
A number of meetings have been held in recent months to discuss the future of transfer pricing in Africa. African governments, along with developed countries around the world, are proving their commitment to build up the transfer pricing systems in sub-Saharan Africa but a number of challenges stand in the way. Sophie Ashley builds a picture of transfer pricing today; how far has it come and how far does it need to go? June 02, 2011
-
The OECD ministerial meeting in Paris had a strong focus on both tax and the developing world and, as such, transfer pricing issues were also raised. June 01, 2011
-
Two recent cases in the US, Medtronic and Guidant, highlight the Obama administration’s budget proposals to clarify the law regarding foreign intangible assets. June 01, 2011
-
The Chinese State Administration of Taxation (SAT) has broadened its audit focus and will pay more attention to intangibles, controlled foreign companies (CFC) and thin capitalisation. June 01, 2011
-
Cristiane Magalhaes and Victoria Rozsavolgyi of Machado Associados, Brazil, comment on the main aspects and difficulties of the adjustments to business conditions allowed by the Brazilian transfer pricing legislation in part one of a two-part investigation. June 01, 2011
-
By Marianna Dozsa and Bettina Dorfer PwC, Austria June 01, 2011
-
The resignations of Mary Bennett and Caroline Silberztein from the OECD last week provoked wide-spread speculation, above all because their jobs were advertised simultaneously, suggesting all is not well in the OECD’s corridors of power. June 01, 2011
-
By Isabel Verlinden, Leticia Ortega and Jurgen Meersman of PwC, Belgium May 27, 2011
-
The draft reportable tax position (RTP) schedule, effective July 1 2011, will require some corporate taxpayers to disclose information regarding reportable tax positions as a supplement to their annual income tax return, bringing more uncertainty for transfer pricing arrangements. May 26, 2011
-
The leading female practitioners in Europe for tax, transfer pricing, tax dispute resolution and trusts and estates advice will be honoured at the first European Women in Business Law awards in London on June 29.
May 26, 2011
-
Media reports suggest a US clothing manufacturer has been issued with a subpoena (government writ) over its transfer pricing, but the reasons remain unknown. May 25, 2011
-
Brazil has updated its guidelines for thin capitalisation, including new measures. May 25, 2011
-
Draft regulations on the French thin capitalisation rules have been released by the French tax authority (FTA). May 25, 2011
-
In the latest transfer pricing case to emerge in Canada, the taxpayer has won a judgment from the Tax Court over reassessments made by the Canada Revenue Agency (CRA) worth about C$2.7 million ($2.7 million) even though the taxpayers’ transactions were found to contravene the arm’s-length principle. May 25, 2011
-
In the Canadian Alberta Printed Circuits (APC) transfer pricing case, the decision relied extensively on the evidence given by expert witnesses on behalf of the taxpayer and the Canadian Revenue Agency (CRA). May 25, 2011
-
The IRS has named Samuel Maruca, of Washington law firm, Covington & Burling, as its first transfer pricing director. May 24, 2011
-
The jobs of both Caroline Silberztein, the OECD's head of the transfer pricing unit in the tax treaty, transfer pricing and financial transactions division, and Mary Bennett, the head of the division itself, were advertised by the OECD in May.
May 24, 2011
-
By Javier González Carcedo and Leticia Ortega of PwC, Spain May 24, 2011
-
While addressing a seminar organised by the Associated Chambers of Commerce and Industry of India, on May 12 2011, R N Dash, the director general of international tax, said transfer pricing cases shall now be subject to audit by the comptroller and auditor general (AG) of India. May 20, 2011
-
The EU’s Joint Transfer Pricing Forum (JTPF) has been accused of bias because of its composition. May 18, 2011
-
On March 11, Japan was rocked by the most powerful earthquake it has ever recorded. But, following the devastation, wrought by the aftershocks and tsunami, the fallout was not just nuclear. The earthquake may have a number of transfer pricing consequences too. May 18, 2011
-
The OECD has sent out a report that welcomes the Russian’s progress towards the revision of its transfer pricing law. May 18, 2011
-
The permanent establishment (PE) panel at International Tax Review’s Asia Tax Executives’ Forum in Singapore last week discussed the movement of employees and to what extent this could constitute a PE. May 18, 2011
-
By Henry An and Wonyeob Chon of Samil PwC May 18, 2011
-
The OECD’s proposed Global Forum for transfer pricing, which will institutionalise the involvement of developing countries, may detract from the UN’s tax committee and the work it is doing for developing countries, a spokesman for a non-governmental organisation has told TPWeek. May 17, 2011
-
By Alexander Voegele and Jean-Benoit Voegele of NERA Economic Consulting May 17, 2011
-
Panelists at the April 2011 International Bar Association, International Fiscal Association 11th Annual Tax Planning Strategies, US and Europe conference in Paris discussed a key aspect of the current OECD project on the transfer pricing of intangibles, namely the specification and resolution of the intangible issues that can arise in a business restructuring. May 11, 2011
-
The Dutch government has rejected the recent EU proposals for a Common Consolidated Corporate Tax Base (CCCTB), citing a number of key objections to the proposals including the issue of allocation keys. May 11, 2011
-
Corporate tax executives should translate chapter nine of the OECD’s Transfer Pricing Guidelines into simpler language should be translated by corporate taxpayers so their company's management can better understand them, so said Sharon Tan, senior tax director for Nike in the Asia Pacific region, at the International Tax Review Asia Tax Forum in Singapore today. May 11, 2011
-
By Vinita Chakrabarti and Rohan Phatarphekar of KPMG and Waman Kale and A. Pradeep of B S R & Co.
May 10, 2011
-
Five African governments will convene in South Africa next month to discuss SABMiller's transfer pricing strategies in the continent. May 06, 2011
-
Taxpayers can no longer use companies with segmental results, or those with a comparatively low turnover, as a comparable for benchmarking purposes under transfer pricing provisions in India. May 04, 2011
-
The Irish Revenue Commissioners has confirmed that a small number of transfer pricing audits will take place later this year. May 04, 2011
-
The world’s attention has turned to Pakistan after the killing of Osama bin Laden, but companies will be keeping an eye on the country for different reasons as it considers introducing transfer pricing documentation requirements in the upcoming budget. May 04, 2011
-
By Daniel Rybnik of EnterPricing May 04, 2011
-
The OECD is inviting public comment on the meaning of beneficial ownership due to the number of differing interpretations by courts and tax administrations. May 03, 2011
-
China’s State Administration of Taxation (SAT) has confirmed it initiated 178 transfer pricing investigations in 2010 and concluded the same amount. April 28, 2011
-
The Thai Revenue Department (TRD) has issued a questionnaire for taxpayers to provide details of their related-party transactions, increasing the scrutiny they apply to transfer pricing arrangements. April 27, 2011
-
By Paul Balkus and Melissa Heath of Ernst & Young April 26, 2011
-
By Daniela Camargo, Marta Milewska and Fred Barrett of PwC April 26, 2011
-
The transfer pricing panel at International Tax Review’s annual Asia Forum in Singapore next month promises to live up to its reputation as one of the most popular panels at the event. April 26, 2011
-
A campaign is building for the introduction of the inter-quartile range and the acceptance of multiple-year data for transfer pricing documentation in India – a country that goes against the global best practice. April 26, 2011
-
The updated members list for the EU Joint Transfer Pricing Forum (JTPF) has been announced. Their mandate is effective from April 1 2011. April 26, 2011
-
Computer company IBM has lost a two-year dispute with the Australian Tax Office (ATO) over royalties paid to its American parent. April 20, 2011
-
When Dave Hartnett, HMRC's permanent secretary for tax, told the Tax Planning Strategies meeting in Paris, organised by the IBA, the ABA, IFA and the OECD, that the UK is to lead a survey into the practicality of global transfer pricing guidelines, you could be sure that practitioners around the world would have an opinion. April 20, 2011
-
The tax authorities in Luxembourg issued Circular LIR 164/2 bis, on April 8, which serves to clarify transfer pricing rules for resident taxpayers. April 20, 2011
-
Advance pricing agreements (APAs) in the US continue to grow in popularity, statistics indicate. April 19, 2011
-
The top official at HM Revenue & Customs confirmed that the UK is to lead a survey into the practicality of global transfer pricing guidelines.
April 14, 2011
-
Caroline Silberztein, head of the OECD’s transfer pricing unit, has said the organisation's guidance on intangibles is insufficient, as it stands, and considered old and out-of-date.
April 14, 2011
-
The deadline for the OECD's project on the transfer pricing aspects of intangibles has been described as ambitious by some and unrealistic by others.
April 14, 2011
-
A new tax law is effective in Qatar with specific transfer pricing implications, including advance rulings. April 13, 2011
-
By Peter Flipsen and Anouc van den Berg, of Simmons & Simmons Amsterdam. April 13, 2011
-
April 13, 2011
-
The Department of Finance in Dublin said it is unlikely to adopt the recommendations of a group of six Irish charities to adapt the transfer pricing regime. April 13, 2011
-
The number of field audits may be increasing globally, but the auditors’ approach in each jurisdiction is not the same. April 13, 2011
-
Media company, Bloomberg, will not appeal a Russian court decision that said its Russian operations constituted a permanent establishment (PE). April 13, 2011
-
A Norwegian Court of Appeal ruled on March 2 that Dell AS, a Norwegian commissionaire company, constituted a sales agency permanent establishment (PE) in Norway because of its undisclosed Irish principal. April 11, 2011
-
April 07, 2011
-
Six Irish charity organisations, collectively called the Debt and Development Coalition Ireland (DDCI), have called on their government to reform the transfer pricing regime. April 06, 2011
-
The IRS has issued a Chief Counsel Advisory (CCA) discussing the application of the valuation methods described in the temporary cost sharing regulations. April 06, 2011
-
Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC). April 06, 2011
-
A decision of the Supreme Court will give taxpayers involved in contentious matters in India the chance to deal with specialists in the future. April 06, 2011
-
By Sylvain Chevrier of Taj, Société d’Avocats, member of Deloitte April 05, 2011
-
By Hannu-Tapani Leppänen and Reima Linnanvirta of Alder & Sound April 05, 2011
-
By Hans-Martin Jørgensen and Nick Pearson-Woodd, Deloitte, Oslo. April 01, 2011
-
How to efficiently and meticulously analyse licensing agreements. David Jarczyk and Daniel Jarczyk of ktMINE explain. April 01, 2011
-
A UK taxpayer said India is a “totally unreasonable” jurisdiction in which to do business. March 31, 2011
-
Caroline Silberztein, head of the OECD’s transfer pricing unit, hinted that credit ratings and guarantee fees may be the next project for the OECD, after the transfer pricing aspects of intangibles.
March 30, 2011
-
The Czech Republic is to set up a new specialised tax authority, for enterprises whose annual turnover is more than CZK2 billion ($115 million).
March 30, 2011
-
Two of India’s leading tax officials have warned taxpayers that poor documentation and misleading information will be pounced upon by the tax department. March 30, 2011
-
Developed countries have committed themselves to the transfer pricing training of African tax administrators. March 28, 2011
-
Taiwan has issued draft thin capitalisation guidelines, following the introduction of rules in January. March 28, 2011
-
The Canada Revenue Agency has been given leave to appeal the GlaxoSmithKline case to the Supreme Court. A cross-appeal from the taxpayer was also accepted. March 25, 2011
-
Valuation was the focus of the Working Party 6 meeting on the transfer pricing aspects of intangibles, which took place between March 21 and 23 at the OECD in Paris. March 24, 2011
-
Advisers have said the reason behind the delay for transfer pricing rules in Russia is because of unresolved issues about substance, including the mechanism for correlative adjustments and the provisions dealing with the period in which the tax authorities can conduct transfer pricing audits. March 23, 2011
-
The change to India’s 5% margin, for the determination of the arm’s-length price, made in the recent budget, was intended to simplify the process for taxpayers but it has only created further confusion. March 23, 2011
-
Canada’s fiscal year 2011 budget was announced yesterday and, while transfer pricing will not undergo any direct changes, provisions in the budget will have a knock-on effect. March 23, 2011
-
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador March 23, 2011
-
When Jeffrey Owens, director of the OECD’s Centre for Tax Policy and Administration (CTPA), announced he would leave his post in January 2012, the tax profession around the world started to speculate about who his successor would be. March 22, 2011
-
The Mumbai Income Tax Tribunal (ITAT) has sent back the file of Teva India, dealing with pharmaceuticals, to the transfer pricing officer (TPO) to reassess whether Vimta Labs, a contract research and testing organisation with abnormally high profit, is comparable to a contract R&D provider. March 22, 2011
-
The Australian Tax Office (ATO) released new guidance on its advance pricing agreement (APA) programme last week. March 17, 2011
-
The heightened scrutiny of transfer pricing is caused by a greater government focus on tax base protection, said KPMG’s Global Transfer Pricing Review. March 17, 2011
-
The European Commission today unveiled its proposal for a common consolidated corporate tax base (CCCTB) system for calculating the tax base of businesses operating in the EU. March 16, 2011
-
A Johannesburg Tax Court decision suggests taxpayers should be able to prove the arm’s length nature of domestic, as well as cross-border, intra-group transactions. March 16, 2011
-
When the Indian budget announced that transfer pricing officers’ (TPO) power would be extended to the power of survey, allowing them access to taxpayers’ premises to validate functional analysis, it provoked strong reactions from practitioners. March 15, 2011
-
A source from the European Commission has spoken exclusively to TPWeek about the common consolidated corporate tax base (CCCTB) proposal, before it was announced today. March 15, 2011
-
Last year was a milestone for transfer pricing in Romania and set a trend of aggressive tax audits and transfer pricing adjustments.
Adrian Luca and Andreea Jora of Transfer Pricing Services in Bucharest provide an update on the latest legislative and practical developments.
March 15, 2011
-
A legal battle between Exportadora Bananera Noboa (EBN), Ecuador’s largest corporate conglomerate, and the Tax Administration (SRI) is coming to an end in Ecuador, setting important precedents for the transfer pricing of commodities. Alexis Carrera, of Ernst & Young in Quito, analyses the case. March 15, 2011
-
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador March 14, 2011
-
Charles River Associates (CRA) has appointed a new vice president in its transfer pricing division. March 10, 2011
-
The OECD is inviting comments on its new project on the administrative aspects of transfer pricing.
March 10, 2011
-
The Brazilian Taxpayer’s Council, responsible for analysing federal tax appeals, and the Brazilian Federal Regional Court have issued decisions, favouring the Brazilian Revenue Service (BRS), over the resale minus method (RMM) for calculating a transfer pricing adjustment. March 09, 2011
-
Last week’s budget in India included a boost to the transfer pricing officer’s (TPO) power, allowing them access to a taxpayer’s premises to obtain information about the arm’s length price (ALP) methodology. March 09, 2011
-
It seems the Internal Revenue Service (IRS) is preparing for the next round of transfer pricing controversy, which may prove to be a real barn-burner. March 09, 2011
-
A new tax Bill which was heard and voted for in principle in the Greek parliament last week, and which will be voted on again next week, means investment firms are now exempt from the application of thin capitalisation rules. March 09, 2011
-
One of the largest automobile companies in the world has closed the book on a long-winded transfer pricing battle, which dates back to the mid-1990s. March 09, 2011
-
China poses a number of problems for taxpayers when evaluating the repatriation of profit in the case of intangible assets. March 09, 2011
-
French companies are showing an increased interest in tax planning because of global competitiveness and the economic downturn, advisers have told TPWeek. This is having an effect on profit allocation. However, public opinion is making taxpayers think twice about using structures that are seen to avoid too much tax. March 04, 2011
-
The Mumbai Income Tax Appellate Tribunal (ITAT) has ruled that a taxpayer’s past transactions cannot be used as a comparable uncontrolled price (CUP) for the purpose of benchmarking a transaction. March 02, 2011
-
Socialist Party members of the French parliament, the largest party of the French centre left, have voiced their concern about the necessity of the R&D tax credit and its future benefit. March 02, 2011
-
Luxembourg tax legislation makes reference to the arm’s-length principle in the different articles of the Luxembourg Income Tax Law (LITL). March 02, 2011
-
The Court of Appeal has ruled that UK thin capitalisation legislation is compatible with EU law, overturning a previous decision, on appeal from HM Revenue & Customs (HMRC). February 28, 2011
-
Draft legislation on Australia’s controlled foreign company (CFC) rules and the tax treatment of certain foreign income has been released in an attempt to modernise the system. The changes mean tougher transfer pricing enforcement. February 28, 2011
-
India’s budget, announced Monday, could make India one of the strictest transfer pricing regimes in the world, according to advisers.
February 28, 2011
-
Foreign banks with permanent establishments (PE) in the UK may have difficulty in providing an accurate calculation for the bank levy, which was introduced in January this year. February 25, 2011
-
Last week’s US budget extended the debate about the future of a lower corporate tax rate, but it also made some more concrete transfer pricing proposals. February 23, 2011
-
The common consolidated corporate tax base (CCCTB) is a recurring debate in the Eurozone. A draft proposal is expected by the end of March. If it is implemented, companies will have to rethink how they organise their tax and transfer pricing affairs in the EU. February 23, 2011
-
After more than a decade since guidance was last issued, HM Revenue & Customs (HMRC) has issued a full statement of practice which will give taxpayers greater clarity on its approach to the underused mutual agreement procedure (MAP). February 23, 2011
-
By Cristiane Magalhães and Ana Lúcia Castagnari Marra of Machado Associados February 23, 2011
-
Li Ying, transfer pricing director at Siemens China, talks to Sophie Ashley about her personal experience with cost
sharing, dealing with the authorities and why China’s attitude to copyright is stopping companies from
transferring their IP to the country. February 22, 2011
-
A UK economist has told TPWeek that UK taxpayers do not want lawyers and accountants to approach them with tax planning arrangements because the risk of being exposed by the media is too great. February 22, 2011
-
The Brazilian Ministry of Revenue (BMR) is helping exporters by tweaking its approach to transfer pricing again. February 22, 2011
-
Steven Tseng has left KPMG, in Hong Kong, where he was the Asia Pacific Regional leader for Global Transfer Pricing Services (GTPS) as well as the partner in charge of GTPS in China and Hong Kong. February 18, 2011
-
Michael Danilack, Deputy Commissioner of the Large Business and International Division (LB&I) at the Internal Revenue Service (IRS) announced yesterday, during the Tax Council Policy Institute’s conference in Washington DC, that a new transfer pricing director will be appointed to LB&I within days. February 18, 2011
-
The Indian finance minister’s comments to the press last month about the inadequacies of the country’s transfer pricing norms have provoked a new wave of hope for future clarity, reports a KPMG correspondent. February 18, 2011
-
Diego González-Béndiksen has been appointed transfer pricing director at DIAN, Colombia’s tax revenue service.
February 17, 2011
-
The Italian Austerity Package, issued in May last year, gave companies the chance to provide transfer pricing documentation to avoid audits or face penalties ranging from 100% to 200%. February 16, 2011
-
The operating methods of multinationals across the world are under greater scrutiny from tax authorities. In particular, transfer pricing and permanent establishment (PE) are more closely monitored. February 16, 2011
-
The Delhi Income Tax Appellate Tribunal (ITAT) has ruled that transfer pricing provisions do not apply if the assessee is not subject to tax in India. February 16, 2011
-
After a decree, issued on June 30 2010, proclaiming an administrative simplification of tax compliance, Mexican taxpayers have the option to discontinue the tax certification process (Dictamen Fiscal) that was largely mandatory up until 2010. Jorge Castellon, of Ernst & Young, examines the transfer pricing requirements for taxpayers who choose to opt-out of the process. February 16, 2011
-
The Dutch government has issued a decree on the attribution of profits to permanent establishments (PE). February 16, 2011
-
Michael Honiball, former head of transfer pricing at KPMG in South Africa, has moved to Webber Wentzel as a partner in the tax advisory department. Based in the Johannesburg office, he also consults from Cape Town. February 15, 2011
-
The South African budget, which will be announced on February 23, could give more clarity about thin capitalisation. February 15, 2011
-
When the new uncertain tax position (UTP) form was launched in the US, in December last year, the IRS said it would simplify the disclosure process for uncertain positions and would not change their policy of restraint, relating to the audit process, in requesting work papers from companies. February 11, 2011
-
The credit cycle stage is a critical factor in the context of pricing intercompany loans and other debt instruments. February 10, 2011
-
The scoping document produced by the OECD, for its project on the transfer pricing aspect of intangibles, raises questions about definitions and the status of valuation methods, transfer pricing professionals have told TPWeek. February 09, 2011
-
The assistant director of income tax (ADIT) in Bangalore has rejected the valuation of assets, by a registered valuer, as arbitrary.
February 09, 2011
-
The Brazilian Ministry of Revenue (BMR) is making efforts to preserve its tax base in what has been dubbed a currency war against the Brazilian real. February 09, 2011
-
The Australian Tax Office has released a tax ruling today on business restructuring. February 08, 2011
-
After the OECD’s release of a scoping document, on its new project on the transfer pricing aspects of intangibles, Caroline Silberztein, head of the transfer pricing unit at the OECD Centre for Tax Policy and Administration, talks to Salman Shaheen of TP Week about the issues to be addressed, what areas could not be covered and what form the consultation process will take now. February 07, 2011
-
Guidance from the Luxembourg tax authorities on transactions by group finance companies helps to clarify what is expected of taxpayers.
February 04, 2011
-
A source has revealed that pre-filing talks have taken place, suggesting that China and the UK might be working on their first bilateral advanced pricing agreement (APA). February 02, 2011
-
The APA Program in the US could restrict requests for unilateral advance pricing agreements, where the counterparty affiliate is located in a country that has a tax treaty with the US.
February 02, 2011
-
Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados analyse developments concerning methodology and safe harbours
February 02, 2011
-
Jeff Yuan and Ray Zhu of PwC in Beijing explain how a multinational enterprise and its Chinese subsidiary. set up as a limited function distributor, should deal with a proposed transfer pricing adjustment. February 02, 2011
-
Transfer pricing will feature strongly in the European Tax Awards 2011 which will be presented in London in May. February 02, 2011
-
Transfer pricing will be covered by a number of panels at this year's Asia Tax Executives' Forum in Singapore in May February 02, 2011
-
Canada has cut its corporate tax rate again, but US businesses are unlikely to react quickly to the increased number of transfer pricing adjustments that may result.
February 02, 2011
-
The OECD has released a scoping document on the transfer pricing aspects of intangibles in response to its consultation on the topic last year. January 31, 2011
-
The OECD has revealed that Masatsugu Asakawa is to be appointed the new chairman of its Committee on Fiscal Affairs (CFA). January 31, 2011
-
The transfer pricing and valuation consultants have added advisers to its practices on the east and west coasts. January 31, 2011
-
As audit activity increases, on a global scale, transfer pricing documentation is becoming critical to multinational companies. January 26, 2011
-
The Venezuelan Tax Administration has introduced the procedure for the calculation of the arm’s length range for compliance with the country’s transfer pricing rules. January 26, 2011
-
A recent transfer pricing dispute in China has reiterated the country’s shift from enforcement and administration towards complex transfer pricing issues and alignment with internationally recognised practices. January 26, 2011
-
India’s Finance Minister said yesterday that an upgrade was needed to bring the country’s transfer pricing norms into line with global standards. January 26, 2011
-
Five asset management and research firms have signed up to a Global Financial Integrity (GFI) initiative on financial transparency. January 26, 2011
-
The European Commission announced yesterday it will extend the mandate of the EU Joint Transfer Pricing Forum (JTPF) until March 2015. January 26, 2011
-
The French tax authorities (FTA) have been conducting raids on the offices of French companies in an attempt to prove the existence of permanent establishments (PE). January 24, 2011
-
Enrico De Angelis and Caterina Colling have both joined joined the TPA team in Italy. January 20, 2011
-
Sébastien Gonnet recently transferred to NERA’s Beijing office. January 20, 2011
-
Indonesia’s director general of taxation (DGT) has released Regulation No.69/2010, which outlines the procedural requirements taxpayers should follow if they want to obtain an advanced pricing agreement (APA). January 19, 2011
-
The maximum fine for a Korean taxpayer’s non-compliance in a transfer pricing audit has been increased from W30 million ($27,000) to W100 million. January 19, 2011
-
Serbia plans to crack down on tax evasion by enforcing transfer pricing regulations more strictly as it tries to revive the economy after the international downturn. January 19, 2011
-
The Supreme Tax Court in Germany has clarified that not only did the country’s old thin capitalisation rules not comply with the freedom of establishment provision of the European Community (EC) treaty, but they also infringed the non-discrimination clause of treaties relating to companies resident in non-EC countries. January 19, 2011
-
Taxpayers and revenue authorities in Mexico will have more time in a mutual agreement procedure because of a new rule introduced last month. January 19, 2011
-
In a decision that represents binding case law, the Supreme Administrative Court in Finland has delivered a ruling on the determination of arm’s-length rate of interest in intra-group financing structures. January 19, 2011
-
Rohan Phatarphekar and Manish Bafna, of KPMG, dissect the Mumbai ITAT ruling in the case of Serdia Pharmaceuticals and explain why APIs can constitute a comparable uncontrolled price (CUP) for the import of drugs when the patent has expired. January 19, 2011
-
The Indian tax department has released a five-year vision statement, which mentions forming a group of experts, by March this year, to tackle tax leakage and transfer pricing. January 12, 2011
-
The most recent set of US competent authority statistics, for fiscal year ending September 30 2010, show the authority completed more cases than in any of the previous five years but the overall processing time has increased. January 12, 2011
-
Nidera, an Argentine grain producer and distributor, is being investigated by the Argentine revenue authority (AFIP), after being accused of transfer pricing manipulation. January 12, 2011
-
The Thai revenue department intends to look at how it could reform its transfer pricing regulations, in particular, by introducing thin capitalisation rules, to increase revenue collection and close loopholes. January 12, 2011
-
Representative offices (RO) and other foreign employees, who split their salary payments between China and their home country, may need to comply with China’s transfer pricing regulations for the 2010 audit period. January 12, 2011
-
The proposed 2011 Japan tax reform includes transfer pricing recommendations designed to mirror the changes made to the OECD guidelines, which were updated last year. January 12, 2011
-
A new transfer pricing consultancy opened its doors in Amsterdam on November 1. January 12, 2011
-
Kristin Yoshida has joined the Houston office of KPMG as a managing director of the transfer pricing services team. January 12, 2011
-
In light of several recent developments in Indian transfer pricing, Rohan Phatarphekar
and Vinita Chakrabarti, of KPMG, provide an overview of key cases and legislation.
January 05, 2011
-
On December 2 2010 the Brazilian government granted the exclusion of Spanish holding companies (ETVEs) from its grey list of privileged tax regimes. Isabel Bertoletti, Fabíola Costa Girão and Henrique de Freitas Munia e Erbolato of Machado report on the run-up to the removal. January 05, 2011
-
Taxpayers in Russia will have to wait much longer than they thought for new transfer pricing rules after the State Duma failed to adopt the law in time for their enactment, as expected, on January 1. January 05, 2011
-
Canada’s Federal Court of Appeal (FCA) has dismissed the Crown’s appeal in the GE Capital Canada (GECC) transfer pricing dispute over the payment of a guarantee fee by a subsidiary to its parent. January 05, 2011
-
Changes to New Zealand’s thin capitalisation rules will come into effect on April 1 2011 as part of the Taxation (GST and Remedial Matters) Act. The act will limit foreign multinationals’ scope to reduce their New Zealand tax liability. January 05, 2011
-
Another year provides further scope for transfer pricing development. Tax directors, transfer pricing advisers and government officials are invited to share their views on what to expect from transfer pricing in 2011. January 05, 2011
-
Boston Scientific, an international producer of medical devices, announced on Tuesday that the Internal Revenue Service (IRS) in the US has issued the corporation with a notice of deficiency, outlining unpaid taxes and interest.
January 05, 2011
-
China has joined Korea, Japan, the US, Canada, Australia and Italy as one of the first countries to issue a comprehensive report about its Advance Pricing Arrangement (APA) programme. Spencer Chong, Qisheng Yu, and Steven Tseng, of PwC, discuss the contents of the report and its implication for taxpayers. January 05, 2011
-
India’s Finance Ministry is reconsidering the introduction of safe harbour rules because of the difficulties in implementing them. December 22, 2010
-
As emerging economies struggle with the prospect of inflation and depreciation, which some tax markets fear could repeat the 1997 Asian Financial Crisis, transfer pricing rules could become increasingly important. December 22, 2010
-
The Belgian tax authorities have finally published a circular clarifying the scope of a year-old law, requiring companies to report all payments made to tax havens that are more than a total of €100,000 ($131,000) in the tax year. December 22, 2010
-
The French Parliament, on December 15, adopted an amendment to the thin capitalisation rules, bringing all financing between related parties, within the scope of the limitations of the rules. December 22, 2010
-
A chain of pharmacies has cut its UK tax bill by £80 million ($125 million) since it left the London Stock Exchange and moved its tax residency to Switzerland, despite a rise in sales and trading profits. December 20, 2010
-
Multinational companies in Italy run the risk of being audited if they do not comply with new guidance on transfer pricing documentation. December 20, 2010
-
Anthony Mahon and Andy El Zayaty of Deloitte provide a guide to the transfer pricing requirements in Egypt. December 15, 2010
-
Cheil Communications India, a subsidiary of South Korea’s largest advertising agency, has won its appeal at the Indian Income Tax Appellate Tribunal (ITAT) over pass-through costs in a case that sets a precedent for future disputes. December 15, 2010
-
Thomson Reuters has added new tools to its Documenter software, a key component to its comprehensive ONESOURCE Transfer Pricing offering. December 15, 2010
-
The Egyptian Tax Authority (ETA) has launched transfer pricing guidelines, after the introduction of legislation in 2005. December 13, 2010
-
Cristiane M. S. Magalhães and Iara M. S. Sousa do Amaral of Machado Associados explains why a decision of the Federal Regional Court of Appeals of the 3rd region (TRF) may become an important precedent for transfer pricing in Brazil. December 13, 2010
-
Draft clauses for Finance Bill 2011 in the UK refer to the updated OECD guidelines of July 2010 and make clear that, for accounting periods beginning on or after April 1 2011, this version is the one for business to refer to. December 10, 2010
-
The Vietnamese government has released a list of jurisdictions that it considers to be tax havens. The list includes the British Virgin Islands (BVI), as well as Bosnia-Herzegovina, UAE, Lithuania, Albania and a number of other countries. December 08, 2010
-
The Delhi Income Tax Appellate Tribunal upheld, in the case of Abhishek Auto Industries, the company’s arm’s-length justification of the payment of a royalty fee for technical know-how and assistance to a manufacturing entity. December 08, 2010
-
The US-Canada arbitration provisions represent a turning point in cross-border transfer pricing negotiations between the two trading partners. December 08, 2010
-
ActionAid, the UK-based development agency, has accused SABMiller, a multinational brewing and bottling company, of using transfer pricing to lower its tax bills in developing countries. December 08, 2010
-
A two-year transfer pricing dispute between the Fijian tax authority and the US subsidiary of Fiji Water has escalated in recent weeks with the company cancelling operations after the government raised tax dramatically. December 07, 2010
-
Canadian and US tax authorities released a memorandum of understanding (MOU) on November 26 about the mandatory binding arbitration proceedings under the mutual agreement procedure (MAP) of the US-Canada tax treaty. December 07, 2010
-
The National Tax Agency (NTA) of Japan has released statistics for tax audits, year ending June 30 2010 (FY 2009). December 01, 2010
-
In the Coca Cola India case the Supreme Court said that, because the writ position could not establish the facts of the case, the taxpayer must adopt proceedings before the assessing officer or transfer pricing officer. Hasnain Shroff and Rajan Iyer, of KPMG in Mumbai, analyse the case. December 01, 2010
-
Diminishing revenues because of economic turmoil across the globe is leading tax authorities to increase their enforcement activity, especially in transfer pricing. December 01, 2010
-
A member of the EU Joint Transfer Pricing Forum has said the latest changes to the OECD transfer pricing guidelines fall into three categories. December 01, 2010
-
China completed its second bilateral advance pricing agreement (BAPA) in October. However, some transfer pricing professionals believe the process is not working properly. November 30, 2010
-
Transfer pricing could be the biggest obstacle to equalising the corporate tax rate in the north and south of Ireland, a UK parliamentary committee has been told. November 29, 2010
-
Honduras is preparing new legislation to combat tax evasion, including a chapter on transfer pricing, as part of its fiscal reform. November 24, 2010
-
Venezuelan tax authorities have penalised 68 taxpayers that failed to comply with the country’s transfer pricing rules. November 24, 2010
-
Cristiane Magalhães and Angélica Santos Torres of Machado Associados examine the changing situation in Brazilian transfer pricing November 24, 2010
-
The Income Tax Appellate Tribunal (ITAT) has held that tax planning carried out within the provisions of the law cannot be classed as a structured transaction for tax evasion purposes, even if the structure saves the company tax. November 24, 2010
-
The Bangalore Income Tax Appellate Tribunal (ITAT) has ruled in favour of the Commissioner of Income Tax in the case of Gemplus India Pvt. November 24, 2010
-
The IRS’ Action on Decision (AOD), on November 10 2010, stating it does not agree with the result or reasoning of the US Tax Court’s decision in Veritas Software Corp. v. Commissioner, brought a spectrum of transfer pricing conflicts to light as the US Tax Court and IRS struggle to find common ground. November 24, 2010
-
The OECD has sent a questionnaire to all member countries asking them how they deal with the issue of hindsight when forecasting the profits arising from intangibles. November 17, 2010
-
Developing countries may not be getting the full benefit of an increased international focus on transfer pricing, says Christian Aid’s senior economic justice adviser. November 17, 2010
-
Fabian Alfonso and Diana Mogollón of BaseFirma believe the tax authorities will only continue to increase the compliance burden for taxpayers November 17, 2010
-
The Tax Directorate General in Indonesia has issued a new regulation on the Joint Agreement Procedure Implementation System to avoid double taxation. November 17, 2010
-
The Chartered Institute of Taxation (CIOT) is launching a transfer pricing option examination paper as a global benchmark of quality and achievement and an independent means of demonstrating transfer pricing expertise. November 17, 2010
-
The introduction of advance pricing agreements in India has been heralded as the “biggest hope” for transfer pricing in the country, said a panel of top Indian tax professionals. November 12, 2010
-
The Kazakhstan tax authorities have made a $1.2 billion claim, including transfer pricing charges against the Karachaganak Petroleum Operating Group (KPO) for unpaid taxes between 2005 and 2008, a Reuters report revealed. November 10, 2010
-
The OECD’s Working Party 6, of the Committee on Fiscal Affairs, met yesterday in Paris to discuss a new project on the transfer pricing aspects of intangibles, which may lead to a revision of chapters six and eight of the transfer pricing guidelines (TPG). November 10, 2010
-
On November 3, FMC Technologies (FMC), an oil and gas equipment services company, announced that it reached a resolution with the IRS about a proposed adjustment to the company’s federal income tax returns for the 2004 and 2005 tax years. November 10, 2010
-
Douglas Fone, Global Partner of Transfer Pricing Associates, explores the implications of new transfer pricing guidelines in Indonesia November 10, 2010
-
Shiv Mahalingham of Alvarez & Marsal (Taxand UK) deconstructs international approaches to APAs and explains how the agreements can help prevent unexpected adjustments, interest or penalties in transfer pricing audits. November 10, 2010
-
Philippine government sources indicated this week that the Bureau of Customs (BOC) is profiling vehicle imports from a number of other companies which have been allegedly undervalued. November 03, 2010
-
Norway has stepped up its scrutiny of related-party transactions, explain Merethe Bryn and Amrit Paul Singh of Deloitte November 03, 2010
-
The Australian Tax Office (ATO) has published the final version of a controversial Taxation Ruling (TR 2010/7) about the interaction between the country’s transfer pricing and thin capitalisation rules. November 03, 2010
-
Rohan Phatarphekar and Vinita Chakrabarti of KPMG discuss the case which led the Supreme Court to suggest that the transfer pricing rules should also apply to domestic transactions November 03, 2010
-
An OECD consultation may lead to an update to its transfer guidelines on transfer pricing on the issue of intangibles and cost-sharing arrangements said David Ernick, associate international tax counsel at the US Department of Treasury, at the Tax Executive Institute’s (TEI) annual conference on October 26. November 02, 2010
-
The Delhi bench of the Income-tax Appellate Tribunal in the case of Sona Okegawa Precision Forging Ltd (2010-TII-41-ITAT-DEL-TP), has examined the issue of duplicative services and whether royalty can be paid to the associated enterprise (AE) for sales made to the AE itself. October 27, 2010
-
France’s new documentation requirements are helping clients to iron out the creases in their transfer pricing policies. October 27, 2010
-
Indonesia’s new transfer pricing rules only confirm what taxpayers believed to be the case already, advisers say. October 27, 2010
-
Tax planning by US software firm, Google cuts overseas tax rate to 2.4%. October 27, 2010
-
In an exclusive interview, Algirdas Šemeta, European Commissioner for Taxation and Customs Union, Audit and Anti-Fraud, said that a common consolidated corporate tax base (CCCTB) will end transfer pricing disputes between member states and taxpayers within its zone. October 20, 2010
-
An executive measure on interest deduction between related parties was issued in Brazil almost a year ago. But, as Ana Lúcia Marra and Cristiane Magalhães of Machado Associados explain, there is still some doubt about when it applies from. October 20, 2010
-
Taxpayers have until next May to prepare for the introduction of changes to South Africa’s transfer pricing regime. October 20, 2010
-
Caroline Silberztein, head of transfer pricing at the OECD’s Centre for Tax Policy and Administration, talks to Salman Shaheen of TP Week about why it launched an initiative on intangibles and what the market has been saying about the things it should cover. October 13, 2010
-
The OECD is considering public comments received from taxpayers, advisers and organisations that represent tax professionals that could revise chapters VI and VIII of its transfer pricing guidelines (TPG). October 13, 2010
-
Taxpayers that have not kept up with transfer pricing requirements in Vietnam have until October 20 to regulate their affairs if they do not want to pay a penalty. October 13, 2010
-
International Tax Review will present its fifth annual Asia Tax Awards at the Fullerton Hotel in Singapore on November 23 2010. October 12, 2010
-
Spencer Chong and Phillip Mak of PricewaterhouseCoopers emphasise that the tax authorities intend to enforce the rules against all companies that fall within them, not just large multinationals October 06, 2010
-
The Italian Tax Administration has now issued a ruling to follow up on the transfer pricing documentation, law decree 78, enacted in May and converted into law July 30 2010. October 06, 2010
-
Two firms shared the top transfer pricing prizes at International Tax Review’s Americas Tax Awards 2010, which were held in New York last week. October 06, 2010
-
Indian taxpayers have expressed concern about the impending changes to the country’s transfer pricing system, despite the adjustments not being implemented until April 2012. September 29, 2010
-
Indian taxpayers have expressed concern about the impending changes to the country’s transfer pricing system, despite the adjustments not being implemented until April 2012. September 29, 2010
-
HM Revenue and Customs in the UK has released a draft Statement of Practice on advance pricing arrangements (APAs) to update its 1999 statement.
September 29, 2010
-
Regulations enabling binding, unilateral advanced pricing agreements (APAs) in Austria will be effective from January 1 next year. September 29, 2010
-
Gordon Hands and John Hollas of CUFTanalytics provide a new perspective and transfer pricing methodology for this relatively common but often misunderstood intra-group financial transaction. September 28, 2010
-
HM Revenue & Customs (HMRC) in the UK have said they will accept the use by companies of the spread methodology, as the basis for determining the amount to include in their cost base. September 22, 2010
-
Dutch taxpayers are so determined to eliminate transfer pricing disputes that they are using tax officers as tax advisers, said a leading tax professional. September 22, 2010
-
Countries are responding in different ways to the new OECD transfer pricing guidelines, which were updated this year after some years of discussion. September 22, 2010
-
Cristiane Magalhães, Alexandre Gentil and Pedro Lima of Machado Associados discuss how Brazil has widened the application of transfer pricing rules to privileged tax regimes September 22, 2010
-
The draft statement of practice contains some welcome features, such as an openness to arbitration and more guidance on when invoking the mutual agreement procedure is appropriate, believe Murray Clayson and Danny Beeton of Freshfields Bruckhaus Deringer September 22, 2010
-
The realigned Large and Medium Sized Business (LMSB) division at the IRS will “leverage the international expertise” at the agency to create a specialised group with service-wide responsibility for the IRS’s international programme, say government officials. September 22, 2010
-
The interaction of the arm’s-length standard and thin capitalisation rules is becoming a key issue in transfer pricing, an economist said at International Tax Review Transfer Pricing Forum in Amsterdam last week. September 22, 2010
-
The debate on the future of the arm’s-length standard (ALS), at International Tax Review's Global Transfer Pricing Forum in Amsterdam today, concluded that, while interesting arguments exist for an alternative method, the ALS is the only viable option because of its close connection to what happens in the market.
September 15, 2010
-
Taxpayers need to pay special attention to the structures and value-added approaches to their sourcing operations, a group of leading tax professionals said today.
September 15, 2010
-
A group of tax directors and advisers came up with an obvious solution to the risk of transfer pricing disputes at International Tax Review’s 10th Global Transfer Pricing Forum in Amsterdam.
September 15, 2010
-
In a TPWeek roundtable, tax disputes specialists discuss alternative dispute resolution (ADR) and whether there is a place for a formal mediation process in the UK. September 10, 2010
-
Tax authorities from across the world should pay close attention to the way the Dutch authorities interact with taxpayers, a leading tax adviser has said. September 08, 2010
-
The Chinese tax authorities have formally signed the first automotive-related Mutual Agreement Procedures (MAP) completed in China, which is also the first successful MAP case in Guangdong Province. September 08, 2010
-
The Intercompany financial transactions talk at International Tax Review’s Transfer Pricing Forum in Amsterdam this month will be moderated by Antonio Russo of Baker & McKenzie in the Netherlands. September 08, 2010
-
Australia boasts impressive advance pricing agreement (APA) statistics. To ensure they stay ahead, the Australian Tax Office (ATO) is planning a significant overhaul of the system, a government spokesperson explains. September 06, 2010
-
The panel titled Technology-based IP and Transfer Pricing at International Tax Review’s Global Transfer Pricing Forum, will focus on the migration of trade IP, dealing in practice with distributed IP development, franchising technology intangibles, variable royalty structures, recurring tax audit themes and US and OECD developments. September 06, 2010
-
Advisers and business representatives will come together at International Tax Review’s Global Transfer Pricing Forum to share experiences in transfer pricing over the last year and deliberate how the new OECD guidelines will affect them. September 06, 2010
-
Marketing intangibles is something that taxpayers should not take lightly as no single approach applies to all business, says one leading transfer pricing adviser. September 01, 2010
-
On August 30 2010, the Indian government tabled a Direct Tax Code Bill 2010 in the parliament. The new code aims to replace the Income Tax Act 1961 and the Wealth Tax Act 1957. If enacted, it will be effective from April 1 2012. September 01, 2010
-
The first topic up for discussion at International Tax Review's Global Transfer Pricing Forum in Amsterdam next month is the future of the arm’s-length standard. September 01, 2010
-
The Danish tax authorities have caused a stir among corporate taxpayers by releasing an action plan which will probably lead to a crack down on transfer pricing. September 01, 2010
-
The dispute resolution panel at International Tax Review's Global Transfer Pricing Forum will focus on planning transfer pricing policies to avoid disputes, achieving settlements and using advanced pricing agreements (APAs).
September 01, 2010
-
The Australian Taxation Office (ATO) has lodged an appeal to the Full Federal Court of Australia against the recent transfer pricing decision in the SNF case. September 01, 2010
-
Taxpayers need to pay special attention to the structures and value-added approaches to their sourcing operations, a group of leading tax professionals has said. September 01, 2010
-
The report from the Joint Committee on Taxation (JCT) on President Obama's 2011 budget, provides revenue estimates for each of the tax provisions in the budget, including proposals about transfer pricing and treatment of intangibles. August 31, 2010
-
After several years of competent authority discussion, a home appliances manufacturer has agreed terms on an advance pricing agreement (APA) with the Chinese tax authorities. August 31, 2010
-
International Tax Review will present its fifth annual Americas Tax Awards at the Waldorf-Astoria Hotel in New York on September 29 2010. August 25, 2010
-
A valuation specialist from the World Customs Organisation (WCO) will give a keynote address at International Tax Review’s Global Transfer Pricing Forum in Amsterdam on September 15 and 16. August 25, 2010
-
The Large and Mid-Size Business division of the Internal Revenue Service (IRS) will become the Large Business and International (LB&I) division on October 1 in a move that signals a greater focus on transfer pricing. August 24, 2010
-
The Canadian mutual agreement procedure (MAP) programme saw an increase in the number of accepted and completed cases in the past year. August 19, 2010
-
Tatiana Villani and Anna Cecília Brasil of Machado Associados comment on the main differences between Brazil’s transfer pricing rules and the OECD’s guidelines, and the difficulties and opportunities that this may create for taxpayers. August 17, 2010
-
Shiraj Keshvani served until March this year as the chief economist for Canada Revenue Agency’s (CRA’s) competent authority services division and was the national coordinator for the advance pricing arrangement (APA) programme. August 13, 2010
-
The Japanese tax authorities have ordered Hewlett-Packard Japan to pay ¥23 billion ($270 million) in unpaid taxes. August 13, 2010
-
The UK Pensions Regulator’s decision to issue its second ever Financial Support Direction against 25 companies in the Nortel Group in Canada, the US, Europe and Africa is because, in part, of an investigation into the telecommunications group’s transfer pricing arrangements. August 04, 2010
-
The period of Canada’s Advance Pricing Arrangement (APA) programme that concluded on March 31 2010 saw an all-time high in active cases, but questions about staffing issues still linger. August 04, 2010
-
GlaxoSmithKline Canada has won its appeal against a 2008 judgment by the Tax Court of Canada that it paid a Swiss related party too much money for the active ingredient in Zantac. August 02, 2010
-
The House Ways and Means Committee’s hearing on transfer pricing issues revealed concern over US corporations’ ability to remain competitive internationally but did not disturb the general consensus around the arm’s-length standard. July 28, 2010
-
Yvonne Cypher joined the firm in 1997 and specialises in transfer pricing with a particular focus on business restructuring. July 28, 2010
-
The OECD has approved updates to the Transfer Pricing Guidelines in its first major revision since they were released in 1995. July 28, 2010
-
A new circular telling local tax bureaux to carry out a nationwide evaluation of taxpayers’ 2008 and 2009 contemporaneous transfer pricing documentation (CTPD) was released on July 12 by the Chinese tax authorities. July 28, 2010
-
Her Majesty’s Revenue and Customs (HMRC) is to release figures relating to the negotiation of advance pricing agreements (APAs) and “other aspects of transfer pricing” imminently. July 27, 2010
-
Cristiane Magalhães and Victoria Rozsavolgyi Bortolin of Machado Associados advise taxpayers in Brazil on when it is best to look for alternative methods to use when establishing transfer prices. July 27, 2010
-
Hasnain Shroff and Vinita Chakrabarti report on the Mumbai Tribunal’s ruling in the case of M/s Cheminova India Limited where a higher price paid to associated enterprises was accepted as the arm’s-length price, due to adequate commercial considerations. July 26, 2010
-
As part of the overhaul of Greece’s tax system, transfer pricing rules have been strengthened, including raising the penalty for not submitting documentation to 20% of the amount of the transaction. July 21, 2010
-
A service provider has become one of the first companies to take a transfer pricing dispute to the Supreme Administrative Court. July 21, 2010
-
A report on transfer pricing from the Joint Committee on Taxation (JCT) in the US has used private company information to outline case studies in a report which concluded that US rules are open to abuse. July 21, 2010
-
Hasnain Shroff, Vinita Chakrabarti and Akash Arora discuss the Nimbus Communications Ltd Vs ACIT, Mumbai (ITA No.2361 (Mum.) of 2007) case and its implications for transfer pricing. July 20, 2010
-
Steven Tseng, China partner in charge and Asia Pacific leader for KPMG’s global transfer pricing services is moving to PricewaterhouseCoopers in China, at the same time as many new appointments are made in the US. July 16, 2010
-
Australia’s assistant treasurer has released for public comment a discussion paper that represents a further step towards reforming the country’s controlled foreign company (CFC) rules. July 16, 2010
-
Companies adopt a wait and see attitude to Russia’s new transfer pricing rules. July 14, 2010
-
On June 30 2010 a new decree was published in the Mexican Federal Official Journal, which grants new administrative relief to taxpayers. July 14, 2010
-
The Australian government hopes to use international information exchange as part of an increased scrutiny of transfer pricing arrangements. July 13, 2010
-
David Borkovec has been made a partner in the PricewaterhouseCoopers tax and legal services department in Prague. July 13, 2010
-
Helga Marie Andresen and Merethe Bryn of Deloitte in Norway discuss the court’s ruling in the landmark case of ConocoPhillips, which shifted the tax authority’s approach to evaluating whether Norwegian companies receive their part of the profit compared to the group as a whole. July 12, 2010
-
The company reported making a loss of A$107.9 million ($94 million) after being hit with a tax adjustment reportedly relating to intercompany transactions. July 12, 2010
-
The Delhi High Court has issued a landmark ruling providing guiding principles on the applicability of the arm’s-length standard to the realm of marketing intangibles. July 12, 2010
-
The OECD has announced it may begin a project to investigate the issues of transfer pricing involving intangible property, much to the approval of specialists in the field. July 07, 2010
-
Fashion retailer, H&M, has been criticised for its operations in Bangladesh and tax payments amounting to transfer mis-pricing. July 07, 2010
-
Gianmarco Monsellato and Sylvain Chevrier of Taj, a member of Deloitte Touche Tohmatsu, answer commonly asked questions about the implementation of the new French documentation rules. July 06, 2010
-
Citrix Systems, a provider of IT solutions, has announced it has settled with the IRS in the range of $12 million to $15 million over disputes about transfer pricing and intellectual property transfers. July 06, 2010
-
The Chinese tax authorities have identified transfer pricing and anti-avoidance as their main priorities for 2010 and have begun to target to specific industries. July 06, 2010
-
Taxpayers are looking into how a common corporate tax base might affect transfer pricing after a new report into how to complete the EU single market lent support to the plans of Algirdas Šemeta, European commissioner for tax, to introduce a proposal on the measure. July 06, 2010
-
International Tax Review’s 10th annual Global Transfer Pricing Forum will be an opportunity for transfer pricing professionals from business, government and private practice to focus on the key issues in related-party transactions. July 06, 2010
-
The Brazilian Congress has passed thin capitalisation rules that will affect the deductibility of interest payments, among other things. July 05, 2010
-
The Indonesian directorate general for tax (DGT) has reinvigorated the campaign to crack down on transfer pricing abuse by meeting with advisers from different firms and asking for input before new guidelines are released. July 05, 2010
-
Robert Kirschenbaum has moved from Baker & McKenzie to join Miller & Chevalier Chartered in Washington, DC. July 01, 2010
-
Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil. June 30, 2010
-
After 21 years with Ernst & Young, Mike Patton is leaving the firm to join DLA Piper. June 30, 2010
-
The Federal Board of Revenue (FBR) in Pakistan believes pharmaceutical companies have used transfer pricing to evade Rp500 million ($5.8 million) in taxes. June 30, 2010
-
An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
June 30, 2010
-
Canadian law firm Blake Cassels & Graydon has taken two tax litigators from rival McCarthy Tétrault.
June 29, 2010
-
Pendo Advisors, a corporate finance and valuation advisory firm in Chicago, has announced the addition of Dan Bourgeois, who has a tax and transfer pricing background, as a managing director June 29, 2010
-
Bruce Clements of Kennesaw State University discusses the dangerous area of establishing an economic connection with States in the second of a three-part discussion of state and local considerations in US business planning. June 28, 2010
-
The Australian parliament has finally passed reforms to the country’s thin capitalisation rules. June 28, 2010
-
The conclusion of a bilateral advance pricing agreement (APA) between the US and the Netherlands will allow FEI, a scientific instruments company, to release large valuation allowance and tax reserves from its accounts for the second quarter of 2010. June 28, 2010
-
Chinese taxpayers are being urged to revisit their transfer pricing policies after the tax authorities announced that it is increasing its scrutiny of the country’s automotive industry. June 23, 2010
-
The Indian government has released a revised discussion paper on the controversial Direct Tax Code (DTC) containing several provisions that will affect transfer pricing. June 23, 2010
-
Transfer pricing documentation requirements introduced under Law decree number 78 will provide clearer guidance for Italian taxpayers. June 23, 2010
-
The UK coalition government’s first budget contained some provisions that will interest transfer pricing practitioners and cause alarm among the financial industry in particular. It also raised the prospect of a general anti-avoidance rule in the UK. June 23, 2010
-
Fred O’Riordan, formerly with the CRA, talks about moving into the private sector and reveals his hopes for the future of arbitration between the US and Canada.
June 23, 2010
-
The General Tax Bureau (GTB) in Uruguay has extended the deadline for corporate income tax (CIT) payments due after the application of the transfer pricing regime and provided additional guidelines about related parties' status. June 22, 2010
-
Eduard Sporken and Neil Schaatsbergen provide background information on APAs/ATRs in the Netherlands and comment on the related statistics recently published by the Dutch tax authorities. June 22, 2010
-
China and India have leapt up the table to join Japan at the top of the latest TPWeek poll to find the most aggressive transfer pricing officials in the world. June 16, 2010
-
The Brazilian government has added 14 new jurisdictions to their blacklist of privileged tax regimes. June 16, 2010
-
Samir Gandhi, Manisha Gupta and Radhi Raman of Deloitte in India discuss the overzealous use of penalty provisions in the country. June 16, 2010
-
Companies operating in Poland are being forced to remain vigilant to avoid falling foul of the country’s strict transfer pricing rules which require documentation submitted in Polish within seven days of request. June 16, 2010
-
Elen Orsini has left the Brazilian Federal Revenue Service and joined Machado Associados. June 15, 2010
-
In Tax Briefing Issue 07 of 2010, released on June 10, the Irish tax authorities have issued guidance on the documentation that is required from taxpayers to comply with the new transfer pricing rules. June 15, 2010
-
Alexis Carrera of Ernst & Young in Ecuador explains that the Ecuadorian tax administration seems to be straying further from transfer pricing best practices and the OECD guidelines. June 15, 2010
-
As part of a firm-wide restructuring, Vaish Associates has promoted two transfer pricing associates to salaried partner level. June 11, 2010
-
The Mexican tax authorities have extended the deadline for companies to submit their 2009 statutory tax reports (dictamen fiscal), though advisers say that transfer pricing documentation still needs to be ready well in advance of the new date. June 11, 2010
-
Akin Gump Strauss Hauer & Feld is opening a new office in Geneva, Switzerland. New partner Jonathan Ivinson has significant transfer pricing experience. June 11, 2010
-
The OECD will review and revise its transfer pricing guidance on intangibles later this year in an effort to clarify one of the most frustrating and notoriously inconsistent areas of international tax. June 10, 2010
-
A mutual agreement between the Netherlands and the US which amends the procedure of obtaining an exemption from dividend withholding tax under the Netherlands-US tax treaty makes sense as it affords the US government responsibility for deciding if US entities qualify for relief under the treaty. June 09, 2010
-
Advisers report consistent attrition at Canada Revenue Agency (CRA) and this along with new initiatives and internal protocols is causing a severe backlog in audits and advance pricing agreement (APA) applications. June 09, 2010
-
An Indian court has outlined the three criteria that taxpayers must satisfy to constitute a fixed place permanent establishment. June 09, 2010
-
Tax directors from multinational companies expressed alarm over shifts in transfer pricing trends during a panel at the joint American Bar Association and International Fiscal Association event in Copenhagen. June 09, 2010
-
The Delhi bench of the Income-tax Appellate Tribunal has upheld the exclusion of non-operating incomes like interest, dividends and income from share trading while determining profit margin under the transactional net margin method (TNMM). June 08, 2010
-
New transfer pricing rules failed to be passed into law within the Constitutional deadline, creating controversy as to which rule applies to transactions carried out since the beginning of the year. June 07, 2010
-
A mutual agreement has been settled between the competent authorities of the Netherlands and the US which amends the procedure by which US pension funds obtain an exemption from dividend withholding tax under the Netherlands-US tax treaty. June 02, 2010
-
An annual study has called for African countries to deal with transfer pricing abuse to help move towards more effective, efficient and fair taxation across the continent. While in South Africa, new transfer pricing proposals fail to cover all the changes that were hoped for. June 02, 2010
-
On May 31 the Italian government issued law decree number 78 (to be converted into law within a 60 day maximum term) that introduces transfer pricing documentation requirements in the Italian statutes. June 02, 2010
-
The Australian Tax Office (ATO) has today released a draft taxation ruling on the application of transfer pricing provisions in business restructurings. June 02, 2010
-
The Norwegian tax authorities recently won its overhead costs case against Enterprise Oil Norway (EO) in the Norwegian courts, because EO could not provide sufficient documentation to show that it had received the services that it had paid for. May 28, 2010
-
The tax authorities of Jiangsu, the third largest province in China by GDP and the fifth largest by population, arranged a tax summit to discuss transfer pricing with taxpayers on May 25. May 28, 2010
-
Waman Kale and Vinita Chakrabarti report on a judgment by the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) relating to the information technology, business process outsourcing sector. May 27, 2010
-
K R Girish and Rohan Phatarphekar of KPMG discuss the reported agreement reached by the Indian and US competent authorities. May 26, 2010
-
Brian Trauman has joined KPMG's economic and valuation services practice as a principal and the new East region leader of the transfer pricing controversy services practice. He will be based in New York. May 26, 2010
-
Australian taxpayers are being warned not to give too much information to the country’s tax authorities after a questionnaire was distributed targeting multinational company transfer pricing policies. May 26, 2010
-
Jennifer Ryan, director of the international tax division at Canada Revenue Agency admits there is “no fairness” in transfer pricing documentation penalties. May 26, 2010
-
The Chinese State Administration of Taxation (SAT) and the Hong Kong Inland Revenue Department (IRD) held a joint seminar earlier this month in the first public exchange between the two authorities about transfer pricing. May 26, 2010
-
The release of the first guidance on the use of the Thai advance pricing agreement (APA) system has been met with approval by advisers. May 26, 2010
-
Cristiane Magalhães and Henrique Erbolato of Machado Associados Advogados e Consultores in Brazil discuss how the country's complex transfer pricing rules affect cost sharing agreements. May 24, 2010
-
Vietnamese taxpayers have just over two weeks to prepare for new transfer pricing guidelines after the Ministry of Finance recently unveiled a list of substantial changes to existing laws. May 19, 2010
-
Transfer pricing panellists at the Asia Tax Executives’ Forum in Singapore last week stressed the importance of documentation to any taxpayer’s policy in this area May 19, 2010
-
PricewaterhouseCoopers retained its title as European Transfer Pricing Firm of the Year at International Tax Review’s European Tax Awards in London last night. May 19, 2010
-
Asia’s senior tax officials are gathering this week in Seoul to discuss ways to tackle transfer pricing abuses in the region. May 17, 2010
-
Bruce Clements, associate professor of accounting and taxation in the Michael J Coles College of Business at Kennesaw State University and practising CPA delivers the first of a three-part discussion of state and local considerations in US business planning. May 17, 2010
-
The Transfer Pricing Practice is the part of the Large and Mid-Size Business (LMSB) division of the Internal Revenue Service (IRS) that is working to "strategically and systematically administer transfer pricing issues". May 14, 2010
-
The Indian and US competent authorities have reached an agreement over transfer pricing disputes relating to the mark-up for the software services provided by Indian enterprises to related parties. May 14, 2010
-
Rohan Phatarphekar and Hasnain Shroff in India continue TPWeek’s discussion about the DRP process and expand on the practical implementation aspects. May 13, 2010
-
Stefaan De Baets, First Attaché of Finances at the Belgian Finance Ministry, along with representatives from the country’s competent authority and the transfer pricing audit teams reveal how ECJ rulings may alter transfer pricing in the country. May 12, 2010
-
A draft bulletin officiel des impôts released by the French tax authorities, intended to help taxpayers and practitioners understand the changes to transfer pricing rules in the country has instead deepened the confusion. May 12, 2010
-
Rahul Mitra and Navneet Kothari of PricewaterhouseCoopers in India call for transfer pricing experts to be mandatorily involved in Dispute Resolution Panels (DRP) decisions. May 11, 2010
-
One of the world’s largest technology companies is challenging the Indian Directorate of Revenue Intelligence’s biggest claim to date. May 11, 2010
-
The Australian government has enraged the mining industry with the announcement of a 40% super tax, in the Henry Tax review. The industry is now facing much larger tax burdens which will threaten the transfer prices in place on resources such as coal. May 10, 2010
-
TPWeek is updating its reader poll on the most aggressive tax authorities for transfer pricing. May 07, 2010
-
Tax specialists are praising the OECD’s decision to equalise the methods for allocating income and expenses between controlled entities under the arm’s length principle. May 05, 2010
-
The International Tax Ruling office of the Italian Revenue Agency (IRA) has issued its first advance pricing agreement (APA) bulletin since the country’s APA programme became effective in 2005. May 05, 2010
-
Milap Jain, India’s director general of international tax and transfer pricing, speaks exclusively to TPWeek about his priorities are for 2010 and beyond and how he hopes for greater cooperation with taxpayers. May 05, 2010
-
Alex Cobham, chief policy adviser at Christian Aid, responds to comments in a recent report criticising the charity’s research into transfer mis-pricing. May 05, 2010
-
Discussions about the best use of transfer pricing documentation sparked debate among panellists and audience members over how much information companies should provide and to whom they should give it. May 05, 2010
-
Alberto Pluviano is set to join Charles River Associates in Paris on May 17. May 05, 2010
-
A Chinese tax official has revealed plans to broaden the scope of the country’s anti-avoidance agenda and also provided important statistics from 2009. May 04, 2010
-
Two companies that took on the tax authorities in the US and UK over transfer pricing issues, and achieved positive results, have now reported higher than expected earnings. May 04, 2010
-
The Philippines Bureau of Internal Revenue has established a special team to investigate the transfer pricing activity of multinationals operating within the country. April 30, 2010
-
Hernán Katz of Deloitte in Mexico describes how many transfer pricing difficulties faced by taxpayers in Latin America are linked to the lack of development in the regions’ financial markets. April 26, 2010
-
Hasnain Shroff and Vinita Chakrabarti report on an interesting case, where it was held that in order to determine the arm’s-length price of an international transaction, the arm’s-length margin should be applied only on the international transaction and not on the entire costs or sales of the taxpayer. April 26, 2010
-
China has shown that it is taking a close interest in transfer pricing developments outside its borders by commissioning a translation of an influential international report. April 26, 2010
-
Andréa de Oliveira Ramos and Cristiane Magalhães of Machado Associados in Brazil discuss the important idea of changing fixed profit margins that are used to calculate benchmarks in the country. April 26, 2010
-
Franz Tomasek, head of legislative research and development for the South African Revenue Service (SARS), explains how companies are selected for audit and reveals the many possible methods for dispute resolution available in the country. April 21, 2010
-
The Australian Taxation Office (ATO) sent out about 140 transfer pricing questionnaires in the first two months of this year as part of its Strategic Compliance Initiative (SCI), but taxpayers have complained the questions are vague and ambiguous. April 21, 2010
-
Toray Industries, a leading Japanese chemical manufacturer, has revealed it expects to receive a notice of correction based on transfer pricing issues raised by the Tokyo Regional Taxation Bureau. April 21, 2010
-
Three fiscal authorities in Fiji have signed a memorandum of agreement (MOA) to share information to help them investigate businesses which do not properly document outstanding proceeds from exports. April 21, 2010
-
Relying on the March 22 2010 decision in the Xilinx litigation case, Altera Corporation, a leader in reprogrammable logic devices, is confident it will not face the level of corporate tax it was expecting. April 21, 2010
-
Todd Miller and Michael Friedman of McMillan in Toronto, Canada explain the documentation rules in Canada and how recent treaty developments and court decision will affect taxpayers. April 20, 2010
-
Gordon Hands of CUFTanalytics explains how taxpayers can assess the arm’s-length dividend rate for intercompany preferred share issuances. April 20, 2010
-
Jennifer Shulman has joined the economic advisory and analysis firm as a vice president in its global transfer pricing practice, based in the US, while Makoto Ikeya was promoted to vice president in the Tokyo office. April 16, 2010
-
Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo comment on increasing documentation burdens for taxpayers in Japan. April 16, 2010
-
CRA hires senior manager from Ernst & Young. April 15, 2010
-
The Danish tax authorities have collected DKK 15 billion ($2.8 billion) from transfer pricing audits of 32 multinational companies. April 15, 2010
-
Batanayi Katongera of Olswang explores the practicalities of designing and implementing a dynamic global transfer pricing policy document. April 14, 2010
-
Jacqueline Shek and Dawn Quek of Baker & McKenzie Hong Kong and Glenn DeSouza of TP Management Consulting in Shanghai evaluate some of the unusual aspects of departmental interpretation and practice note number 46 and assess its implications for companies operating in Hong Kong. April 14, 2010
-
Gordon Hands of CUFTanalytics examines two example cases, an interest rate swap and a factoring transaction, where expected loss (EL) is used to price the credit risk portion of the intercompany financial transaction. April 14, 2010
-
A controversial system of global profit reporting is gaining support as the European Commission is asked to examine how country-by-country reporting could become the norm in Europe. April 14, 2010
-
A report published by Jersey Finance concludes the data contained in two studies conducted by Christian Aid is flawed. April 14, 2010
-
India’s new dispute resolution panels (DRP) will continually adapt to a changing tax environment and greatly improve taxpayer litigation consistency, say two of the country’s leading advisers. April 13, 2010
-
India’s director-general of international tax and transfer pricing has said thin capitalisation, advance pricing agreements and safe harbour provisions are his three priorities for the coming year. April 13, 2010
-
Jan-Paul Borman and Amit Chadha of PricewaterhouseCoopers in South Africa discuss how economic pressures and the recent budget have sharpened the tax authorities’ attentions on transfer pricing. April 12, 2010
-
Maxim Alekseyev, Olga Chugunova and Olga Roslova of ALRUD law firm explain what taxpayers need to be aware of before significant changes are introduced to the transfer pricing rules in Russia. April 12, 2010
-
Polish taxpayers have been sent a strong warning after the country’s tax authorities confirmed that they will focus their 2010 audit work on transfer pricing and its associated issues. April 07, 2010
-
In March 2010 HM Revenue & Customs (HMRC) released an update of the guidance in its International Manual on the UK’s thin capitalisation rules. This guidance is prepared primarily to assist inspectors of taxes in applying the thin cap legislation, but also offers useful insights into HMRC policy for taxpayers and advisers. April 07, 2010
-
The deadline for interested parties to submit comments on the new disclosure requirement that would affect many US companies with international dealings has been extended until June 1 2010. April 07, 2010
-
New transfer pricing rules included in the tax reform package announced by the Japanese Ministry of Finance in December finally came into effect on April 1. April 07, 2010
-
Sanjay Sanghvi and Daksha Baxi discuss the landmark E*TRADE litigation and its implications for the India-Mauritius tax treaty. April 06, 2010
-
The State Administration of Taxation (SAT) in China has issued a circular that further clarifies certain aspects of the country’s tax law. April 06, 2010
-
Gordon Hands of CUFTanalytics discusses the merits of external credit ratings and forward-looking probability of default as credit risk measures when selecting comparable uncontrolled financial transactions (CUFTs) April 06, 2010
-
It is hoped the new protocol will boost multilateral cooperation and reduce cross border tax evasion. April 06, 2010
-
A survey by accounting firm KPMG found 82% of respondents said they faced the same level of transfer pricing controversy as last year. In Spain there was a significant increase, however. April 06, 2010
-
Statistics released by the US Bureau of Economics show US companies invested $21.9 billion in Ireland in 2009, only a slight drop from the $22 billion invested in 2008 despite the discussions over introducing transfer pricing rules to the country. March 31, 2010
-
The tax burdens of overseas fee payments from China have unavoidably increased due to the recent issuance of circulars and tax reforms, a leading tax professional has said. March 31, 2010
-
In his 2010 budget speech, Alistair Darling, the chancellor of the exchequer, said that £2 billion ($3 billion) has been raised by the UK bank payroll tax. Advisers believe that this may have implications for financial institutions’ transfer pricing arrangements. March 31, 2010
-
The first-tier tax tribunal in the UK has cast doubt over the UK tax treatment of US limited liability companies (LLCs) in the decision Mr Swift v The Commissioners for HMRC ([2010] UKFTT 88 (TC)). March 31, 2010
-
The US Advance Pricing Agreement (APA) Program has announced it received 127 applications for agreements last year, only four more than in 2008. And yet, the time taken to process important bilateral APAs has increased by more than four months. March 31, 2010
-
Nine firms will compete for the top award of European Tax Firm of the Year at International Tax Review's fifth annual European Tax Awards in London in May. March 31, 2010
-
Fabia Azevedo and Cristiane Magalhães of Machado Associados in Brazil explain how importers can make use of letters of credit to avoid double taxation where country agreements do not help. March 25, 2010
-
Lucijan Klemencic of Ernst & Young explains the transfer pricing documentation requirements in Slovenia. March 24, 2010
-
Multinationals are paying significantly more tax to resolve transfer pricing disputes. With litigation a costly and time consuming option for both the taxpayer and the tax authority, thoughts are turning to alternative dispute mechanisms. March 24, 2010
-
Bulgaria’s National Revenue Agency (NRA) has published guidelines on transfer pricing documentation, finally clearing up what is expected of taxpayers. March 24, 2010
-
Russian multinational companies are already making changes to their transfer pricing policies nine months ahead of the country’s new law, a leading tax professional has said. March 24, 2010
-
TPWeek is proud to announce the 10th annual Global Transfer Pricing Forum will take place in Amsterdam on September 15th and 16th 2010. March 24, 2010
-
The nominees for the national tax and transfer pricing awards in International Tax Review's European Tax Awards 2010 are announced today. March 24, 2010
-
Transfer Pricing Associates (TPA) has entered into a strategic alliance with Bar-Zvi & Ben-Dov, a leading transfer pricing firm in Israel. March 24, 2010
-
The US Court of Appeals for the Ninth Circuit has now affirmed the Tax Court's decision in the Xilinx case. March 22, 2010
-
A decision by the Indian Authority for Advance Rulings concerning permanent establishments (PE) has been heavily criticised by tax professionals and is likely to affect foreign multinationals operating in the country. March 18, 2010
-
The Hungarian tax authorities are focusing their attention on the detailed transfer pricing arrangements of companies, going beyond investigations of documentation compliance that taxpayers are used to. March 17, 2010
-
The deputies of the lower house of the Kazakhstan Parliament (known as the Majilis) have passed a bill of amendments and additions to the country’s laws on transfer pricing. March 17, 2010
-
Hasnain Shroff, Sanjeev Gupta and Tarini Nijhara in India look at the unreported judgement in the case of IL Jin Electronics (India) Private Limited. March 15, 2010
-
The OECD group responsible for consultations on transfer pricing will soon begin to consider the issues concerning the taxation of intangibles, including a comprehensive definition and appropriate valuation methods. March 12, 2010
-
Taxpayers should view litigation as the last resort for resolving transfer pricing disputes, senior tax executives and practitioners told a conference in London. March 12, 2010
-
Transfer pricing executives and their advisers are dismissive of the news that Algirdas Semeta, the new EU tax commissioner, wants to see a common consolidated tax base (CCCTB) in place as soon as possible. March 12, 2010
-
Komatsu, a Japanese construction equipment manufacturer, has announced that it is being investigated by the Japanese tax authorities over transfer pricing concerns. March 11, 2010
-
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
-
China has released a circular that drastically changes the tax rules for foreign companies deriving income through establishments in China. March 10, 2010
-
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
-
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
-
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
-
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
-
TPWeek is adding to the library of documentation guides on TPWeek. This week, Belgium, Japan, Malta and Romania are new. March 03, 2010
-
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
-
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
-
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
-
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
-
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
-
TPWeek is refreshing the content found in the documentation guide section of the website, be sure to take a look. February 25, 2010
-
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
-
Advisers from Machado Associados summarise the new Brazilian transfer pricing rules and tax deductibility requirements. February 25, 2010
-
An eagerly awaited UK transfer pricing case will not now go to court. February 24, 2010
-
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
-
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
-
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
-
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
-
AJ Bamidele of the Nigerian Federal Inland Revenue Service explains to TPWeek how Nigeria administers its transfer pricing regime. February 17, 2010
-
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
-
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
-
Australia will introduce new tax agent services legislation on March 1 which includes information about safe harbour rules. February 17, 2010
-
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
-
Hasnain Shroff and Poonam Ghelani in India look at the important VVF Limited case. February 16, 2010
-
Taxpayers in China need to urgently complete transfer pricing documentation, or face the wrath of the State Administration of Taxation. February 10, 2010
-
The head of the Egyptian tax authority has announced that a circular containing transfer pricing guidelines will soon be released. February 10, 2010
-
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
-
Stig Sollund, director general, tax law department at the Ministry of Finance in Norway answers TPWeek's questions. February 10, 2010
-
Taiwan has released new assessment rules on the applicability of double taxation agreements that will affect permanent establishments in the country. February 10, 2010
-
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
-
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
-
The special bench of Chandigarh Income Tax Appellate Tribunal has restated the critical importance of conducting a detailed FAR analysis. February 04, 2010
-
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
-
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
-
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
-
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
-
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
-
Eduard Sporken and Paul Kraan of KPMG Meijburg & Co explain the changes made to the European arbitration convention. February 01, 2010
-
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
-
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
-
Hasnain Shroff and Vinita Chakrabarti of KPMG in India look at the Global Vantedge case. January 27, 2010
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
A discussion about country by country reporting caused a heated debate at a meeting at the UN this week January 20, 2010
-
Tax professionals from across Africa will meet in Cairo in February to discuss transfer pricing issues affecting the continent. January 20, 2010
-
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
-
International Tax Review will present its fifth annual European Tax Awards at the Dorchester Hotel in London on May 18 2010 January 20, 2010
-
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
-
Specialists at a UN meeting have stressed the importance of building transfer pricing units within the tax authorities of developing nations. January 19, 2010
-
In a frank discussion at a UN meeting of experts, panellists expressed their frustrations about all the available transfer pricing methods. January 19, 2010
-
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
-
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
-
TPWeek will be reporting from the first UN meeting focusing on transfer pricing. January 18, 2010
-
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
-
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
-
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
-
The Singapore government has passed a law that requires taxpayers to comply with the arm’s-length principle. January 13, 2010
-
A mutual agreement procedure (MAP) for transfer pricing adjustments has been established between the Isle of Man and Australia. January 13, 2010
-
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
-
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
-
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
-
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
-
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
-
A new software product could revolutionise the often lengthy and expensive process of translating transfer pricing documentation. January 07, 2010
-
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
-
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
-
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
-
A recent Indian tribunal ruling has emphasised the importance of using comparable data for the purpose of benchmarking controlled transactions. January 06, 2010
-
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
-
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
-
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
-
Paul Flignor, Alan Granwell and Eric Ryan of DLA Piper discuss the landmark Veritas decision and the implications for taxpayers December 18, 2009
-
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
-
The Australian government has released for public consultation draft legislation on proposed changes to the country’s thin capitalisation rules. December 18, 2009
-
Brazil has unveiled legislation that contains the country’s first thin-capitalisation rules. December 18, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
The Indonesian Tax Office (ITO or DGT) is proactively approaching taxpayers and requiring them to answer queries and questionnaires. December 10, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
Taxpayers in South America should expect greater scrutiny from the transfer pricing authorities in 2010, says a leading adviser. December 02, 2009
-
India’s new dispute resolution mechanism has not got off to a good start. December 02, 2009
-
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
-
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
-
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
-
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
-
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
-
KPMG took the top award for transfer pricing at International Tax Review’s Asia Tax Awards in Singapore last Tuesday November 26, 2009
-
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
-
The Australian Tax Office has hired 60 transfer pricing specialists to clamp down on abuses undertaken by large taxpayers. November 25, 2009
-
Nonconforming transfer pricing rules in some Latin American countries are leading to problems with tax treaty negotiations November 23, 2009
-
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
-
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
-
The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 2010. November 19, 2009
-
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
-
Wendy Nicholls and Leela Murugasu of Grant Thornton investigate how deep taxpayers must dive to find suitable comparables today. November 17, 2009
-
Companies operating in China have until December 31 to prepare comprehensive transfer pricing documentation. November 17, 2009
-
Deal reduces the technology company’s tax bill for the fiscal years 2000 to 2006 by $5.2 million. November 17, 2009
-
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
-
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
-
Multinational companies need to adjust their transfer pricing systems rapidly to stave off the revenue-hungry tax authorities, says a report. November 11, 2009
-
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
-
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
-
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
-
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
-
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
-
The Chinese tax authorities have concluded their first bilateral advance pricing arrangement (BAPA) with a European country November 04, 2009
-
When considering the current tax legislative agenda, what implications can we expect for transfer pricing? November 04, 2009
-
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
-
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
-
The Taiwan Ministry of Finance recently introduced guidelines for the determination of Taiwan source income. October 29, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
The Swedish government has announced that it will enact an advance pricing agreement (APA) programme from January 1 2010 October 22, 2009
-
The number of advance pricing arrangements (APAs) has dropped in Australia, figures from the country’s tax authorities have revealed October 21, 2009
-
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
-
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
-
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
-
The Danish tax authorities have recently issued new administrative guidelines on valuation and documentation of intellectual property (IP) transactions. October 15, 2009
-
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
-
The high level of trade conducted through multinational companies in Canada means taxpayers there are subject to intense transfer pricing investigations. October 14, 2009
-
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
-
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
-
Poland has updated its transfer pricing laws with the issuance of two new decrees October 14, 2009
-
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
-
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
-
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
-
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
-
The commissioner for Internal Revenue has lodged the IRS’ response to the petition for rehearing in the landmark Xilinx case. October 06, 2009
-
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
-
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
-
The commissioner for Internal Revenue has lodged the IRS’ response to the petition for rehearing in the landmark Xilinx case. October 06, 2009
-
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
-
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
-
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
-
The number of completed mutual agreement procedures is increasing among OECD countries, new statistics have revealed October 01, 2009
-
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
-
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
-
The Venezuelan tax administration (SENIAT) is continuing a transfer pricing audit campaign for fiscal years 2005 to 2008 October 01, 2009
-
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
-
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
-
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
-
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
-
More information has been released on France’s new transfer pricing documentation requirements September 23, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
President Barack Obama has revealed Michael Mundaca as his nominee for assistant secretary for tax policy, department of the Treasury. September 17, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules September 08, 2009
-
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
-
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
-
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
-
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
-
Transfer pricing will feature strongly when International Tax Review presents its third annual Asia Tax Awards in Singapore on November 24 September 02, 2009
-
In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing. September 01, 2009
-
What does the introduction of advance pricing arrangements mean for taxpayers in India? September 01, 2009
-
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
-
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
-
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
-
An important concession helpful to manufacturers using mainland China contract processors has been denied. August 19, 2009
-
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
-
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
-
What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn? August 17, 2009
-
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
-
Xilinx has filed for a rehearing or a hearing en banc in the latest development in this historic case. August 13, 2009
-
Xilinx has filed for a rehearing or a hearing en banc in the latest development in this historic case August 13, 2009
-
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
-
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
-
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
-
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
-
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
-
Werner Stuffer and Susann van der Ham of PricewaterhouseCoopers in Germany discuss the increase of large transfer pricing audits in Germany August 11, 2009
-
My company is planning to move some operations to Brazil, what are the key transfer pricing considerations in the country? August 11, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
The Australian Customs authorities have released guidance detailing how taxpayers should apply for a valuation advice relating to transfer pricing. July 23, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
Norbert Raschle, Nicolas Bonvin and Mohamed Serokh, PricewaterhouseCoopers July 14, 2009
-
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
-
The UK government is asking for public opinion on new capital gains rules for groups of companies. July 08, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers. July 01, 2009
-
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
-
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
-
Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation. June 30, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
The Sultanate of Oman has finally released details for the country’s first ever set of transfer pricing rules. June 22, 2009
-
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
-
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
-
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
-
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
-
What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form? June 15, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
Joe Andrus and Irv Plotkin of PricewaterhouseCoopers explain how President Obama's recent budget may directly affect transfer pricing June 06, 2009
-
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
-
What documentation do I need to prepare and file by what time for entities in Taiwan? June 04, 2009
-
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
-
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
-
Oman is set to introduce transfer pricing rules in an effort to attract further investment to the country June 03, 2009
-
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
-
My company has entities in South Korea. What are the documentation requirements for those entities? May 27, 2009
-
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
-
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
-
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
-
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
-
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
-
International Tax Review announces the winners of the European Awards 2009. May 20, 2009
-
The Australian government has amended the country’s thin capitalisation rules in response to concerns from the business community. May 19, 2009
-
My company has entities in China. What documentation requirements do I have to fulfil, and when? May 18, 2009
-
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
-
Michael Velten, Angie Ng and Penelope Wong move on from Transfer Pricing Associates in Asia. May 18, 2009
-
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
-
Transfer pricing rules in France face a dramatic overhaul, with stringent new documentation requirements and increased scrutiny on taxpayers expected. May 13, 2009
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
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
-
Car maker Chrysler is closer to a strategic alliance deal with Fiat SpA after eliminating a transfer pricing hurdle that had th