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Steven Tseng and Cheng Chi of KPMG detail the latest changes in China January 06, 2009
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Taxpayers in China will need to submit nine transfer pricing disclosure forms when they file their 2008 tax return next year December 19, 2008
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The banks' compliance burden is set to increase after an order from CBDT December 19, 2008
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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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One of the several controversial aspects of Brazil's transfer pricing legislation is the possibility for taxpayers to take into account the “basket approach” criterion to calculate the parameter price. Henrique de Freitas Munia e Erbolato of Machado Associados explains. December 16, 2008
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HM Revenue and Customs in the UK has released draft legislation that amends the corporation tax rules on late-paid interest between connected companies. December 16, 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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In less than a month, section 140A will be introduced into Malaysia's tax legislation. This new section in the income tax act, 1967 will specifically target transfer pricing issues. These changes will be effective from January 1 2009, so it is crucial that taxpayers understand the implications of the new transfer pricing provisions so that they can be adequately prepared. December 15, 2008
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The amendment to the Polish Accounting Act of March 18 2008, part of which came into force on August 22 2008, has changed the scope of information and data to be provided in additional information to the financial statements December 15, 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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On November 24 2008 the Polish President signed the act of November 6 2008 amending (among other things) the corporate income tax act. The new act introduces regulations concerning transfer pricing issues that will allow taxpayers to eliminate double taxation in transactions concluded with their foreign related parties. December 10, 2008
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Angelika Thies of CMS Hasche Sigle in Munich, Germany explains the latest developments in German transfer pricing December 10, 2008
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The Philippines' wait for transfer pricing regulations is set to continue with the appointment of a new tax chief who, says tax professionals, is in no hurry to introduce any new rules. December 10, 2008
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Following an amendment to the draft law entitled “Market Supervision Authority and other provisions” submitted to the Greek parliament, rules are being introduced for auditing transfer pricing in inter-company transactions. The rules are based on the OECD arm’s length principle December 04, 2008
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Chinese officials finally announce details of the changes to be made to transfer pricing rules December 03, 2008
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Transfer pricing regulations were introduced in Columbia in 2004, Carlos Mario Lafaurie Escorce and Ricardo Suarez of PricewaterhouseCoopers explain the requirements of the laws. December 02, 2008
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Slovakia and Spain have both introduced amendments to bring their legislation into line with the EU transfer pricing forum’s approach to documentation. November 26, 2008
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On November 6 2008, the Taiwan Ministry of Finance released the final ruling to the modifications of the safe harbour ruling (ruling number 09704555160). The finalised ruling modifies the conditions which must be met for profit seeking enterprises to prepare transfer pricing contemporaneous documentation November 26, 2008
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New guidance from China’s State Administration on Taxation (SAT) means that parent companies will now need signed agreements with subsidiaries for service costs to be deductible. November 25, 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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The French tax administration is increasingly turning to the transactional net margin method of determining an arm's length price. Jean-Luc Trucchi argues that rapidity and efficiency should not be used as an excuse for using a simplistic method that may generate a biased application of the arm’s length principle. November 21, 2008
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Hungary’s tax authorities have told taxpayers to comply with the country’s transfer pricing regime or risk facing large penalties November 19, 2008
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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
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Atul Jain and Manisha Gupta of KPMG examine how the Indian tax authorities will approach modern business restructuring November 18, 2008
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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
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Transfer pricing advisers in Thailand are warning companies using a specific holding company investment structure that traditional treatment of their tax liability is changing November 12, 2008