Analysis

• Hungary gets tough on transfer pricing

  Hungary’s tax authorities have told taxpayers to comply with the country’s transfer pricing regime or risk facing large penalties November 19, 2008

• South-East Asia looks to tighten transfer pricing rules

  Countries in South-East Asia are introducing or reforming their transfer pricing rules to increase revenues and attract foreign investment November 19, 2008

• Advisers criticise profit margin in resale price less profit method

  Brazilian transfer pricing rules adopt fixed profit margins in methods applicable to import transactions. Fabia Moreira Azevedo of Machado Associados explains why many are critical of the percentage profits margins allowed under the rules November 18, 2008

• Business restructuring is under the transfer pricing spotlight

  Batanayi Katongera of Thomson Reuters warns corporations everywhere that business restructurings are under more scrutiny than ever before in light of the OECD discussion draft on the topic. November 18, 2008

• Indian authorities scrutinise cross-border restructuring

  Atul Jain and Manisha Gupta of KPMG examine how the Indian tax authorities will approach modern business restructuring November 18, 2008

• Marketing intangible assets can lead to exit taxes

  In France, the concept of marketing intangible assets has led the tax authorities to imposing taxes on companies. Jean-Luc Trucchi explains what is happening. November 18, 2008

• India should introduce APAs and change data rules

  Rahul Mitra of PricewaterhouseCoopers outlines the flaws in the Indian transfer pricing regime and explains why changes need to be made to support multinational companies operating in the country November 10, 2008

• Russia must strengthen transfer pricing rules

  Russia’s weak transfer pricing regime is hindering the countries development and making the country less attractive to foreign investment, says a leading professional firm November 03, 2008

• Singapore proposes transfer pricing guidance for loans and services

  The Inland Revenue Authority of Singapore (IRAS) has published a draft supplementary circular to provide guidance on the application of the arm’s length principle to related party loan and service arrangements.  October 28, 2008

• Double taxation treaty between Spain and Colombia approved

  The new tax treaty between Spain and Colombia contains transfer pricing implications. Here Moises Curiel and Diego Gonzalez-Bendiksen of Baker & McKenzie outline the treaty elements.  October 22, 2008

• New Brazilian rules clarify how to obtain changes in profit margins

  Carlos Eduardo Costa MA Toro and Carlos Eduardo de Biasi of Zilveti Sanden Advogados believe that new rules on requesting a reduction in the presumed profit margin are a step forward for Brazilian transfer pricing October 22, 2008

• Taxpayer wins Argentine verdict on technology transfer payments

  Daniel Rybnik of EnterPricing says that taxpayers in Argentina should be aware of the different treatment of transfer pricing policies based on variable and fixed factors October 22, 2008

• Canadian implications of the OECD restructuring discussion draft

  Greg Noble and Alfred Zorzi, both partners at Ernst & Young in Canada summarise what the OECD business restructuring draft will mean for Canadian taxpayers October 20, 2008

• Korean National Tax Service releases APA annual report

  The Korean National Tax Service recently published its 2007 APA annual report, Henry An of Samil PricewaterhouseCoopers describes some of the key elements of the report October 15, 2008

• Mandatory arbitration makes debut in Canada-US treaty

  Santino Di Libero of Gowling Lafleur Henderson believes the inclusion of mandatory arbitration in the fifth protocol to the Canada-US treaty will help the competent authority process between the two countries October 15, 2008

• Transfer pricing is slow to catch on in South America

  Transfer pricing rules have been in place in certain South America jurisdictions for many years but so far, little action has been taking by either taxpayers or the aurthorities. October 14, 2008

• Key issues of Turkish advance pricing agreements

  Ramazan Biçer, senior transfer pricing specialist in the transfer pricing division of the Turkish revenue administration, highlights the key issues of advance pricing agreements in Turkey  October 08, 2008

• Using credit default swaps to price intercompany loan guarantees

  Harlow Higinbotham and Stuart Harshbarger of NERA Economic Consulting discuss the use of credit default swaps to price intercompany loan guarantees. October 07, 2008

• Anticipating business restructuring documentation requirements

  John Hughes of Mayer Brown explains how taxpayers must raise the bar on transfer pricing documentation to stay inline with the new OECD discussion draft. October 06, 2008

• CRA maintains focus on transfer pricing audits

  Christopher Steeves of Fraser Milner Casgrain analyses the recent CRA report on the mutual agreement procedure program. October 05, 2008

• Reconsidering the Mexican Maquiladora paradigm

  Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 05, 2008

• South African companies accused of shirking payments

  Taxpayers in South Africa have been pushing the boundaries of tax compliance by taking contentious positions on transfer pricing, the annual report of the South African Revenue Service (SARS) says.  September 30, 2008