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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
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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
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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
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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
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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
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The OECD’s report on how some companies create losses through aggressive tax planning is not revolutionary, by their own admission, but taxpayers say governments are missing a trick. September 02, 2011
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Forget player transfers, it’s transfer pricing that could put Manchester City Football Club under the microscope of football’s governing body, UEFA. August 31, 2011
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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
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Vodafone is one of four companies Christian Aid is trying to convince to support country-by-country reporting with its FTSE4 campaign. August 10, 2011
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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
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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
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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
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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
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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
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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
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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
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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
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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
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India’s budget, announced Monday, could make India one of the strictest transfer pricing regimes in the world, according to advisers.
February 28, 2011
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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
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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
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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
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The credit cycle stage is a critical factor in the context of pricing intercompany loans and other debt instruments. February 10, 2011
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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
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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
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The US-Canada arbitration provisions represent a turning point in cross-border transfer pricing negotiations between the two trading partners. December 08, 2010
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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
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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
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Fashion retailer, H&M, has been criticised for its operations in Bangladesh and tax payments amounting to transfer mis-pricing. July 07, 2010
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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
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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
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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
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Samir Gandhi, Manisha Gupta and Radhi Raman of Deloitte in India discuss the overzealous use of penalty provisions in the country. June 16, 2010
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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
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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
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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
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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
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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
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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
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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
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Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo comment on increasing documentation burdens for taxpayers in Japan. April 16, 2010
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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
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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
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Purvez Captain and Steven Wrappe of Ernst & Young discuss the advantages and problems that can be found in adding to in-house professionals’ responsibilities. March 08, 2010
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Hasnain Shroff, A Pradeep and Vinita Chakrabarti highlight the key transfer pricing aspects that need attention in the forthcoming Union Budget 2010. February 24, 2010
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Under pressure from countries who view Ireland as a soft touch for aggressive tax planning, Ireland has introduced new transfer pricing rules in its new Finance Bill. February 05, 2010
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The Indian government will increase taxpayer confidence by allowing advance pricing agreements (APAs) for the first time, but concerns have been raised about how they will be implemented. August 18, 2009
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Transfer pricing theory has long been associated with transactions within multinational companies, but now it is being applied to the exchange of football players between English football [soccer] clubs. July 22, 2009
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The milestone arrangement between China and Denmark is also the first bilateral advance pricing arrangement (BAPA) to be signed since the country’s new transfer pricing regulations were released in January 2009. July 15, 2009
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A Polish contract manufacturer for Plastic AG, a German entrepreneur, delivers the final goods directly to a customer. Now Polish SA takes over and invoices the customer. Does this trigger any German taxes? July 08, 2009
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Authors of a report on tax havens and development, commissioned by the Norwegian government, believe international action is required to deal with the problem of transfer mispricing. June 30, 2009
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Governments should abandon the arm’s-length price and grant multinationals the discretion to set their own transfer prices internally, says a report from the Rotman School of Management at the University of Toronto. June 24, 2009
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Following the conclusion of HM Revenue and Customs first major successful transfer pricing dispute, UK taxpayers are being warned that the authorities are thirsty for more. June 10, 2009
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A leading Indian business lobby group has asked the government to rethink transfer pricing rules and to create a uniform approach for information technology businesses. June 04, 2009
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Taxpayers using transfer pricing to avoid paying tax could have a serious effect on Australia’s tax base, warns the country’s deputy commissioner of taxation. May 27, 2009
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In unprecedented economic times for transfer pricing, some commentators believe that existing transfer pricing models need to change to deal with the situation. May 27, 2009
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Susan George, board chair of the Transnational Institute, a worldwide fellowship of scholar activists, has slammed transfer pricing for being a hindrance to institutions such as the IMF providing financing to emerging nations. May 06, 2009
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A Grant Thornton discussion paper places transfer pricing top of the list of things companies should consider before establishing manufacturing operations to China. May 06, 2009
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A UK charity has called on the world’s leaders to target transfer pricing abuses, amid the fear that it is depriving the world’s poorest countries of an estimated $160 billion. April 22, 2009
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While many of the countries across the region claim to have rules that follow the OECD guidelines, experts take a different view. April 22, 2009
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Taxpayers have told China’s State Administration of Tax that they are concerned about how to apply the new transfer pricing regulations during the economic downturn. April 09, 2009
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New Zealand’s Inland Revenue Department (IRD) has followed through on its threat to get tough on transfer pricing and has warned businesses that they will be investigated if they fail to comply. March 18, 2009
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Latvia’s tax authorities are becoming more aggressive in their approach to transfer pricing and companies need to be better prepared, a tax lawyer has warned. March 16, 2009
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The public comments in response to the OECD’s discussion draft on the transfer pricing aspects of business restructuring have been published on the Organisation’s website.
March 11, 2009
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Jersey and the UK signed a tax information exchange agreement today in London March 11, 2009
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A desperate budgetary situation could lead the Philippines government to finally introduce transfer pricing guidelines, three years after they were initially proposed. March 11, 2009
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A common intercompany transaction between multinational enterprises (MNEs) may result in unforeseen excise tax payments and late filing interest. Matthew Sambrook and Greg Noble of Ernst & Young in Canada explain the dangers. March 09, 2009
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Updated transfer pricing rules released on February 20 place a significant burden on both taxpayers and practitioners, beginning with the calendar year 2008. March 04, 2009
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The cost sharing regulations introduced recently in the US are extremely complicated but offer taxpayers many planning benefits according to one senior transfer pricing adviser. February 25, 2009
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According to the explanatory statement of law number 9,430/96, which governs Brazilian transfer pricing rules, the lawmaker is focusing on avoiding tax evasion by means of undercharging exports or overcharging imports from a foreign related party February 17, 2009
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Taxpayers were warned of the UK government’s dual approach to disregarding transactions at a transfer pricing conference in New York last week. February 10, 2009
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Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HM Revenue & Customs in the UK tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority, offers taxpayers an insight into how transfer pricing cases are selected and talks about the future of transfer pricing. February 05, 2009
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On January 5 2009, the Ministry of Strategy and Finance announced it would revise the enforcement decree of the law for the coordination of international tax affairs concerning transfer pricing disclosure requirements January 09, 2009
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The burden of keeping up with transfer pricing documentation requirements is becoming one of the biggest challenges for multinational corporations, with some taxpayers having to prepare upwards of 500 transfer pricing reports a year
December 17, 2008
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On July 17, the OECD issued its final report on the attribution of profits to permanent establishments, reaffirming the “separate entity approach” that hypothesises a permanent establishment (PE) as a separate and distinct enterprise that may deserve additional compensation according to the arm’s-length principle. The report notes, say Brandon Feldman and Patrick Breslin of the Ballentine Barbera Group, that the OECD transfer pricing guidelines should apply in such cases. December 16, 2008
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Reforming transfer pricing in India will not be top of the agenda in next year’s budget, despite fears that the present system is too aggressive and a hindrance to business development. December 10, 2008
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The Canada Revenue Agency (CRA) recently released its annual report on advanced pricing agreements (APAs) covering the fiscal period ending March 21 2008. December 10, 2008
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During economic downturns, US-based multinationals may find themselves wanting to repatriate cash from foreign subsidiaries. Under such circumstances, transfer pricing may provide a useful mechanism to achieve this in a tax-efficient manner. Mike Murphy, Albert Liguori and Julie Smith of Alvarez & Marsal Taxand explains how December 03, 2008
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China was supposed to have mandatory documentation as of January 1 2008 but the final guidelines are still awaited. Here, Glenn DeSouza summarises the hot issues and shares strategies on dealing with thin capitalisation and documentation. November 25, 2008
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New Zealand’s new government sees transfer pricing as a critical piece in the country’s international tax regime, but is unlikely to tighten the current rules amid a struggling economy, a leading professional says November 11, 2008
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Advisers expect President-elect Obama's administration to put changes to transfer pricing rules high on its list of priorities when he takes office November 11, 2008
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Rahul Mitra of PricewaterhouseCoopers outlines the flaws in the Indian transfer pricing regime and explains why changes need to be made to support multinational companies operating in the country November 10, 2008
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Indian employers have called on the government to clarify transfer pricing rules and introduce an advance pricing agreement programme to encourage investment
November 03, 2008
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The Chinese State Administration of Taxation (SAT) is to be restructured to improve transfer pricing rules and enhance the tax administration of the country’s larger companies October 28, 2008
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Sweden tightens transfer pricing regulation October 28, 2008
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The fact that Italy criminalises transfer pricing conflicts was a major example used to demonstrate the problems with asking tax practitioners to comply with all tax laws around the world October 28, 2008
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The introduction of thin capitalisation to the new Chinese Corporate Income Tax Law (CIT) was celebrated by many borrowing enterprises, but many will be left disappointed by its lack of clarity October 28, 2008
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Transfer pricing rules have been in place in certain South America jurisdictions for many years but so far, little action has been taking by either taxpayers or the aurthorities. October 14, 2008
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On September 28 2008 Ecuador's president, Rafael Correa won a referendum on a new constitution that provides significant new powers, including some linked to transfer pricing.
October 08, 2008
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Harlow Higinbotham and Stuart Harshbarger of NERA Economic Consulting discuss the use of credit default swaps to price intercompany loan guarantees. October 07, 2008
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Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 05, 2008
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Patrick Breslin from The Ballentine Barbera Group reports on the potential problems of US-Chinese cost sharing arrangements
September 29, 2008
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An increasing number of countries worldwide are introducing transfer pricing rules in an effort to widen their tax bases and improve enforcement, says a report by KPMG.
September 11, 2008
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The IBON Foundation has hit out at oil companies’ reluctance to disclose how they determine what they charge for their products in the wake of windfall profits in the industry August 19, 2008
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US corporations are using transfer pricing regulations to move profits out of the country to avoid paying federal income tax, said a report from the US Government Accountability Office (GAO).
August 13, 2008
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Advisers believe Australia's tax treaties should not give the authorities an unlimited period in which to launch transfer pricing audits July 02, 2008
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Speaking of the controversial IRS win in the US Court of Appeals for the Ninth Circuit in the Xilinx case, IRS commissioner Douglas Shulman called the decision a “real victory”. June 04, 2008
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Glenn DeSouza, managing director, TP Week correspondent Transfer Pricing Management Consulting (TPMC), an allied firm of Baker & McKenzie January 09, 2008
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TPWeek's snapshot guide to the key points in the Ernst & Young global transfer pricing report December 13, 2007
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Directors fear IRS will review FIN 48 workpapers December 12, 2007
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Mark Atkinson, head of transfer pricing for Deloitte UK, writing exclusively for TP Week, analysies its impact December 11, 2007
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There has been considerable criticism that India fails to accord with OECD guidelines on TP policy. Hardev Singh of KPMG South India argues that it does November 08, 2007
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The ATO is tightening its focus. PwC Australia, in this exclusive article, looks at the implications for taxpayers of its new priorities October 22, 2007
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By Jan Martens (France), John Neighbour (UK), Damian Preshaw (Australia) and Robin Saunders (UK) of KPMG September 27, 2007