Case Study

• Convergence of customs valuation and transfer pricing

  Tax authorities around the world are beginning to note the importance of looking at both transfer pricing and customs valuations when assessing multinational companies’ operations. January 06, 2009

• How exchange rate differences arise in related-party transactions in Poland

  Taxpayers may have to explain why they used a certain exchange rate in related-party transactions. If they cannot they could face higher tax bills, explain Jarosław Bieroński and Bartłomiej Biały of Sołtysiński Kawecki & Szlęzak December 23, 2008

• OECD approach to PEs: When arm’s length agent compensation is enough

  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

• Bangalore Tribunal overturns official’s action

  The Bangalore Tax Tribunal has ruled in favour of the taxpayer in a dispute that covered the powers of a transfer pricing officer to disregard a company’s transfer pricing analysis.  September 30, 2008