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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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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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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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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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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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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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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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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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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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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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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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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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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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Sweden tightens transfer pricing regulation October 28, 2008
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The Chinese State Administration of Taxation (SAT) is to be restructured to improve transfer pricing rules and enhance the tax administration of the country’s larger companies October 28, 2008
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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