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The Brazilian Internal Revenue Service (Brazilian IRS) has published instructions providing the currency appreciation adjustment factor to be used in the calculation of transfer prices for the calendar year 2009. March 03, 2010
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Advisers from Machado Associados summarise the new Brazilian transfer pricing rules and tax deductibility requirements. February 25, 2010
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Amr El Monayer, assistant to the deputy minister of the Egyptian Ministry of Finance explains what the new guidelines will cover, and when they will be released. February 25, 2010
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The head of the Egyptian tax authority has announced that a circular containing transfer pricing guidelines will soon be released. February 10, 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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Under pressure from countries who view the country as a soft touch for aggressive tax planning, Ireland will probably introduce new transfer pricing rules tomorrow when the Finance Bill 2010 is published. The Bill will implement changes announced in the budget in December. February 03, 2010
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Taxpayers face an additional administrative burden under changes to appendix 9 of the Multiple Information Tax Return (DIM), but the acceptance of electronic filings for certain companies will speed up the process of submitting returns. February 03, 2010
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Luiz Felipe Ferraz of Demarest e Almeida in Sao Paulo discusses the nuances of Brazilian tax reforms as an important reform was brought in then quickly reversed in late 2009. January 27, 2010
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Taxpayers and advisers believe yesterday’s discussion document on controlled foreign companies reflects a genuine attempt by the UK tax authorities to respond to their concerns. January 27, 2010
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A document for discussion on the new UK CFC rules will be published by Her Majesty's Treasury and Her Majesty's Revenue and Customs on Tuesday. January 25, 2010
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Hopes are high that more straightforward transfer pricing legislation will be enacted as part of the tax reforms expected in March this year. January 14, 2010
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The application of the transfer pricing rules in Brazil in relation to leasing agreements executed between related parties in Brazil and abroad is a controversial issue. January 12, 2010
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The Japanese government released an outline of its proposal for a 2010 tax reform package on December 22 2009, which is expected to be followed by the 2010 amended tax laws within a few months. January 07, 2010
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The end of the year brought some good news for US taxpayers struggling with liquidity issues after the tax authorities announced they were extending for another taxable year the liberalised rules that permit a foreign subsidiary to make short-term loans to its US parent. January 07, 2010
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The Australian government has released for public consultation draft legislation on proposed changes to the country’s thin capitalisation rules. December 18, 2009
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Brazil has unveiled legislation that contains the country’s first thin-capitalisation rules. December 18, 2009
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Recently new draft tax law provisions have been filed with the Belgian Parliament (Parl St, Kamer, 2009-2010, nr 52-2278/001) for further discussion. December 07, 2009
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Multinational taxpayers in Africa will have to start developing their transfer pricing policies and documentation to deal with the increasing number of countries in the region putting guidelines in place or reforming what it already has. December 02, 2009
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Recent tax changes announced in the Netherlands budget will not affect transfer pricing, but intangibles have become a target for tax authorities November 26, 2009
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The OECD has released a revised discussion draft for a new article seven of its model tax convention, which relates to permanent establishments November 26, 2009
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The Australian Tax Office has hired 60 transfer pricing specialists to clamp down on abuses undertaken by large taxpayers. November 25, 2009
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Nonconforming transfer pricing rules in some Latin American countries are leading to problems with tax treaty negotiations November 23, 2009
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Companies operating in China have until December 31 to prepare comprehensive transfer pricing documentation. November 17, 2009
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Spencer Chong, Cecilia Lee, Charles Chan and Paul Tang of PricewaterhouseCoopers describe how the situation for taxpayers has changed since the overhaul of the China’s transfer pricing rules. November 04, 2009
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Five months after the Sultanate of Oman released information on the country’s first ever set of transfer pricing rules, little is still known about what they cover. November 04, 2009
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New transfer pricing document requirements in Hungary are compliant with EU guidelines and may also simplify procedures for companies active in member states. October 29, 2009
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The Swedish government has announced that it will enact an advance pricing agreement (APA) programme from January 1 2010 October 22, 2009
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China’s State Administration of Taxation (SAT) recently issued the Notice of the SAT on Certain Issues concerning the Implementation of the Articles on Royalty Payment in Tax Treaties (circular Guoshuihan [2009] number 507) October 20, 2009
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New reporting obligations in financial accounts for intercompany transactions and off-balance arrangements and the increasing use by the tax authorities of disclosures in FIN 48 reports to select taxpayers for transfer pricing audits, have complicated companies’ tax affairs in Belgium October 20, 2009
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The Danish tax authorities have recently issued new administrative guidelines on valuation and documentation of intellectual property (IP) transactions. October 15, 2009
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Decree number 392/009 amends and clarifies some of the detailed regulations established by decree number 56/009, which was issued in January 2009. October 05, 2009
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Alexander Voegele and Hendrik Fuegemann of NERA Economic Consulting outline how new administrative guidelines are affecting taxpayers’ application of the relocation of functions regulations in Germany October 01, 2009
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A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of goods purchased by Brazilian legal entities and packed or repacked locally for resale. October 01, 2009
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Loss-making documentation is a catch-22 situation in China. Glenn DeSouza, managing director at Transfer Pricing Management Consulting in Shanghai, which has an exclusive strategic alliance with Baker & McKenzie, explains the difficulties September 17, 2009
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China’s State Administration of Taxation (SAT) has issued a circular that identifies transfer pricing audit targets and specifically provides directives relating to special inspections of non-resident enterprises September 09, 2009
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India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules September 08, 2009
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The introduction of new transfer pricing documentation rules has led to taxpayers facing more frequent and detailed audits of their activities than ever before. August 12, 2009
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Four conglomerates being investigated by the Philippines Bureau of Internal Revenue (BIR) may find relief in the incomplete transfer pricing rules in place in the country. August 06, 2009
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Australia’s tax authorities have vowed to scrutinise taxpayers’ transfer pricing activities and thin capitalisation rules in a bid to help businesses and individuals facing genuine hardship during the economic downturn. August 06, 2009
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Fabia Elaine Azevedo and Cristiane Magalhães of Machado Associados discuss the transfer pricing rules on transactions between a Brazilian compnay and a non-resident related party by means of an interposed person August 05, 2009
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A regulation released earlier this month by China’s State Administration of Taxation (SAT) makes loss-making single-function enterprises submit transfer pricing contemporaneous documentation to justify their losses. July 29, 2009
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On July 24 2009, the Hong Kong Court of Final Appeal (CFA) handed down its decision in the Ngai Lik Electronics Company vs CIR case. July 29, 2009
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Efforts made by one UK crown dependency to enhance its network of international tax treaties have been bolstered this week by the signing of an agreement that includes transfer pricing provisions. July 29, 2009
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The Australian Customs authorities have released guidance detailing how taxpayers should apply for a valuation advice relating to transfer pricing. July 23, 2009
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Vineet Chhabra and Viswanathan Subramaniam of Deloitte India discuss the key budget amendments in the transfer pricing regulations and its implications on the taxpayers and the revenue authorities July 14, 2009
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After eight years of continuous controversy and adjustments, India’s government has outlined a reform package that aims to reduce the number of transfer pricing disputes in the country. July 08, 2009
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Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation. June 30, 2009
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The Australian Taxation Office (ATO) has released an external review of the advance pricing arrangement (APA) programme together with an initial response to the recommendations contained in the report.
June 23, 2009
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The Sultanate of Oman has finally released details for the country’s first ever set of transfer pricing rules. June 22, 2009
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Tarun Arora and Shikha Gupta of PricewaterhouseCoopers outline the problems apparent in the Indian transfer pricing rules and provide suggestions for improving the regulations in the coming budget. June 17, 2009
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The Polish ministry of finance has published a document which identifies areas of possible tax fraud to be investigated, with the aim of raising revenues by catching the cheats. One of the priorities is transfer of income to related parties. June 10, 2009
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Transfer pricing has steadily become one of the number one issues for the Internal Revenue Service (IRS). Alfredo Jay Urquidi of Marsh & McLennan Companies and David Jarczyk of Ceteris discuss. June 09, 2009
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Joe Andrus and Irv Plotkin of PricewaterhouseCoopers explain how President Obama's recent budget may directly affect transfer pricing June 06, 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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The Hong Kong Inland Revenue Department has released a highly anticipated guidance document on transfer pricing and profit allocation. Travis Benjamin and Glenn DeSouza of Baker & McKenzie discuss the development. June 03, 2009
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Oman is set to introduce transfer pricing rules in an effort to attract further investment to the country June 03, 2009
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The Russian tax authorities have issued a framework for the country’s long-awaited transfer pricing reform, meaning taxpayers will soon have to start revising their policies. May 27, 2009
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China’s State Administration of Taxation (SAT) has released guidelines, Guoshuifa [2009] number 90, concerning tax risk management practices of large enterprises. May 26, 2009
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The Australian government has amended the country’s thin capitalisation rules in response to concerns from the business community. May 19, 2009
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My company has entities in China. What documentation requirements do I have to fulfil, and when? May 18, 2009
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The Greek tax authorities have issued a circular that drives home the message to taxpayers that transfer pricing documentation is of extreme importance. May 18, 2009
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Transfer pricing rules in France face a dramatic overhaul, with stringent new documentation requirements and increased scrutiny on taxpayers expected. May 13, 2009
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Two cases before the Tax Court of Canada relate to financial transactions meaning taxpayers with intercompany financial transactions should be prepared for greater scrutiny under newly introduced reporting requirements. May 13, 2009
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Taxpayers in Thailand will be provided with more clarity and confidence for their related-party transactions as the revenue department has begun drafting long-awaited advance pricing agreement guidelines.
May 06, 2009
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As if filing returns under the new corporate income tax regime in China was not difficult enough, the authorities have started moving deadlines around, adding more pressure for taxpayers. 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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Russia will adopt its long awaited revised transfer pricing legislation later this year, a government representative has said April 15, 2009
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The new transfer pricing regulations will bring an increase in audit activity, predicts a senior adviser April 13, 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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Egyptian taxpayers with related-party transactions will soon be required to provide a transfer pricing study to support such transactions under planned changes to the country’s tax laws. April 08, 2009
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It has been discussed whether Brazilian transfer pricing rules apply to the sale of shares and quotas held by Brazilian companies to a related party, as defined by law (including residents in low tax jurisdictions and beneficiaries of privileged tax regimes). April 03, 2009
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The Danish tax authorities made transfer pricing adjustments of more than $1 billion in 2008, almost three times as much as the previous year, even though they finalised fewer cases April 01, 2009
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The Israeli tax authorities have proposed the clarification of the tax treatment of intercompany loans April 01, 2009
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As transfer pricing regulations have been changed each year since they were issued in December 2004, Ecuador seemed to be a less than probable candidate to start transfer pricing audits, reveals Alexis Carrera of Ernst & Young March 25, 2009
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The UK tax authorities have amended draft legislation that will change the corporation tax rules on late-paid interest between connected companies, following initial public response to the proposal March 25, 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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Under long-anticipated regulations published by the US Internal Revenue Service (IRS), cost sharing arrangements (CSAs) remain an effective tool that multinational taxpayers can use to efficiently develop and manage ownership of valuable intangible property among subsidiaries. But valuations of pre-existing, platform intangibles contributed to CSAs will be scrutinised by the IRS going forward March 12, 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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Instructions for completion, guidance formats, and questionnaires related to the review by the registered external auditor (external CPA), and the electronic filing, of the financial audit report for 2008 were published in Mexico’s Federal Register at the end of February. The most relevant (and controversial) aspects of such instructions, formats, and questionnaires have to do with transfer pricing. March 11, 2009
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Taxpayers in China will need to ensure thorough documentation is in place for all transfer pricing after the authorities announced they will be tracking such filings electronically, making monitoring the information and pinpointing companies for audit easier. March 10, 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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The UK’s direct tax law was altered yesterday, as a new draft bill rewriting transfer pricing guidelines was published, though it did not deliver any substantial changes. March 04, 2009
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The Czech Republic looks set to revert to thin-capitalisation rules that existed in 2007 after a vote in the lower house of parliament on Tuesday. March 04, 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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The New Zealand tax authority has stepped up its review of transfer pricing compliance and is set to perform more risk reviews than ever before February 19, 2009
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Uruguay has finally introduced guidelines on the application of transfer pricing rules, over two years after the laws were enacted. 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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On December 31 of each year, Brazilian legal entities must calculate transfer pricing adjustments in order to determine the taxable bases of the corporate income tax (IRPJ) and the social contribution on net profit (CSLL). February 02, 2009
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The new transfer pricing documentation-related penalty rules in the law for the coordination of international tax affairs (LCITA) are effective from December 26 2008. Under the new rules, a Korean taxpayer with related-party transactions is required to prepare and maintain contemporaneous documentation to avoid the 10% penalty on underreported tax. February 02, 2009
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Japan’s National Tax Agency (NTA) has issued a series of amendments to its existing administrative guidelines on transfer pricing, as well as the accompanying reference case studies. January 27, 2009
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Thailand has concluded its first two bilateral advance pricing agreements (APA) seven years after transfer pricing guidelines were introduced to the country. January 27, 2009
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Her Majesty’s Revenue & Customs (HMRC) is expected to change the penalties it imposes on erroneous transfer pricing documentation from April. It is thought that the minimum penalty applied will be 10% of the total tax lost to HMRC although the total penalty will depend on the severity of the error. January 21, 2009
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On December 31 2008, the IRS issued new cost sharing regulations in temporary and proposed form. Mark Bronson of Ceteris explains what taxpayers should be doing to comply with the new rules January 20, 2009
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The Inland Revenue Authority of Singapore (IRAS) issued transfer pricing guidelines for the first time in February 2006. In July 2008 the tax authorities opened a consultation to find out from taxpayers how the guidelines were working and if any changes were required. Chai Sui-Fun, assistant commissioner in the tax policy and international tax division of IRAS, explains the Singapore approach to transfer pricing to Ralph Cunningham of www.tpweek.com January 19, 2009
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Slovakia has enacted an amendment that brings its transfer pricing legislation into line with the documentation requirements of the EU Joint Transfer Pricing Forum. January 14, 2009
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China’s State Administration of Taxation (SAT) released Circular Guoshuifa [2009] number 2 on January 8 2009 which finalised the implementation measures of special tax adjustments, a set of greatly anticipated new regulations on transfer pricing, to be effective starting this past year (FY2008). January 12, 2009
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The Czech Republic government has changed the country's thin-capitalisation rules for the second time in a year. January 12, 2009
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Steven Tseng and Cheng Chi of KPMG detail the latest changes in China January 06, 2009
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The banks' compliance burden is set to increase after an order from CBDT December 19, 2008
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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 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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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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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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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 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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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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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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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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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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Angelika Thies of CMS Hasche Sigle in Munich, Germany explains the latest developments in German transfer pricing 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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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 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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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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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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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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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
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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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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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The Israeli Tax Authority (ITA) recently released the Income Tax Circular No. 3/2008 concerning transfer pricing November 05, 2008
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The Internal Revenue Service wants to tighten transfer pricing rules to stop multinational companies with US operations using them illegally to cut their tax bills
November 04, 2008
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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
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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 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
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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 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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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
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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
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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
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The Ministry of Strategy and Finance announces various proposed amendments to tax laws which include provisions to provide penalty relief to taxpayers maintaining contemporaneous transfer pricing documentation. October 17, 2008
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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
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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
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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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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
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The Netherlands has issued a new mutual agreement procedure (MAP) in a move that will make avoiding double taxation more accessible and transparent for taxpayers.
October 08, 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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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
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Christopher Steeves of Fraser Milner Casgrain analyses the recent CRA report on the mutual agreement procedure program. October 05, 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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Chris Newman and Jon Jenni from Ernst & Young Shinnihon Tax, Tokyo describe possible changes to Japan’s transfer pricing legislation
September 29, 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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Eduardo Goldszal, a partner at KPMG in Portugal highlights the main points of the country’s new APA legislation September 19, 2008
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The Indian government is set to decontrol the pricing of coal and give wide ranging powers, including determining transfer pricing in respect of captive coal and lignite (brown, lowest rank coal) mines, to the regulator.
September 12, 2008
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Malaysian taxpayers will soon be able to apply for advance pricing arrangements September 04, 2008
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Ramazan BİÇER, senior state revenue specialist of the Turkish Revenue Administration, discusses an amendment to transfer pricing law in Turkey that deals with the loss of tax revenue to the National Treasury August 28, 2008
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Alexis Carrera Reyes of Ernst & Young reports on how reform to new thin-capitalisation rules can help taxpayers in Ecuador August 28, 2008
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TPWeek.com correspondent, Machado Associados, points out that rules on customs valuation and transfer pricing resemble each other in some ways, but diverge in others August 26, 2008
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Jarosław Bieroński and Bartłomiej Biały, of Sołtysiński Kawecki & Szlęzak, believe taxpayers should prepare contemporaneous transfer pricing documentation as the tax authorities may ask for them August 26, 2008
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Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador August 21, 2008
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Taxpayers should take a more systematic approach to setting and documenting inter-company transactions as tax authorities worldwide seek to apply transfer pricing regulations more stringently, a new study says.
August 20, 2008
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TP Week.com correspondent Machado Associados points out that there is controversy about how the new definition of tax haven in recent changes to Brazil’s transfer pricing rules should be applied August 14, 2008
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The Inland Revenue Authority of Singapore (IRAS) is assessing how well taxpayers are complying with the country’s transfer pricing guidelines that were issued in 2006 by carrying out a transfer pricing consultation (TPC) programme.
August 07, 2008
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The UK tax authorities have proposed amendments to corporation tax rules on late payments of interest between connected companies August 07, 2008
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Jaroslaw Bieronski and Bartlomiej Bialy of Soltysinski Kawecki & Szlezak highlight the transfer pricing methods allowed in Poland July 14, 2008
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TP Week correspondent Machado Associados reports on safe harbour rules in the Brazilian transfer pricing regime June 19, 2008
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SUNAT issues guidance on filing dates for 2007 tax returns June 19, 2008
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New guidance establishes rights and responsibilities of taxpayers June 19, 2008
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Government also introduces fees for advance pricing agreements June 12, 2008
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New regulations implement 2006 Income Tax law June 12, 2008
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Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil June 04, 2008
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Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008
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Tax authority says it will concentrate on intangibles and restructuring June 02, 2008
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CRA audit focuses on Gildan’s offshore sales and marketing subsidiaries June 02, 2008
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Tax authority announces new structure to change filing requirements May 30, 2008
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Tax authority issues advance notice of key changes May 29, 2008
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KR Girish and Rohit Jain, of TP Week correspondent KPMG in India look at the impact of double tax treaties and transfer pricing May 28, 2008
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Hardev Singh and Saurabh Dhanuka, of KPMG, TP Week’s correspondent in India, give practical advice on dealing with India’s revenue authorities May 22, 2008
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Polish authorities step up scrutiny of related party documents in transfer pricing sweep May 15, 2008
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Finance ministry to issue circular letter to industry and tax profession April 30, 2008
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Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year April 24, 2008
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Swedish Tax Agency proposal covers bilateral and multilateral APAs April 22, 2008
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New amendment gives SARS much wider authority on disclosure April 17, 2008
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Felipe González Martín, of TP Week correspondent firm Garrigues, reports on a critical development for transfer pricing in Spain April 16, 2008
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Spanish National Court sets standard for intra-group services evidence April 14, 2008
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Jonathan Lubick, of Ballentine Barbera, and Henriette Fuchs, of Tadmor Attorneys, in Tel Aviv, describe the documentation evironment in Israel April 09, 2008
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David Stavropoulos and Andrew Spalding, of Deacons law firm, say that the ruling illustrates Tax Office policy on future adjustments April 07, 2008
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Kim Jarrett and Mark Cormack of KPMG New Zealand contrast the tax authorities’ divergent approaches in Australia and New Zealand April 04, 2008
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TP Week correspondent Machado Associados reports on the process for transfer pricing audits in Brazil April 03, 2008
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Kenya, Tanzania, Uganda, Rwandi and Burundi seek year end implementation March 25, 2008
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TP Week correspondent Machado Associados
outlines the environment for transfer pricing documentation in Brazil March 22, 2008
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Tynwald endorses seven-country package including transfer pricing agreements March 19, 2008
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Dunja Hitrec, of Ernst & Young in Zagreb, looks at the Croatian tax authority’s approach to transfer pricing auditing March 15, 2008
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Lucijan Klemencic, of Ernst & Young in Ljubljana, reports on the regime for transfer pricing audits in Slovenia March 15, 2008
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Ernst & Young in Israel explains how companies deal with form 1385 March 14, 2008
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Marius Leivestad and Eivind Falck-Ytter, Ernst & Young in Oslo, examine the new Norwegian transfer pricing documentation rules March 14, 2008
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Joan Hortalà, tax partner, and Neus Mollera, associate, of leading Spanish law firm Cuatrecasas Abogados explain the environment for transfer pricing audits in Spain March 14, 2008
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TP Week correspondent Jacques Van Rhyn, of PricewaterhouseCoopers, explains the environment for transfer pricing audits in South Africa March 14, 2008
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Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008
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In TP Week’s latest international guide, our correspondents report from around the world on the national regimes for transfer pricing audits. March 14, 2008
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Eran Shif, of Ernst & Young in Israel, describes the approach of the Israeli tax authorities to transfer pricing audits March 14, 2008
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Hedvig Solyomvari, of Ernst & Young, reports on the climate for transfer pricing audits in Hungary March 14, 2008
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Mushfig Aliyev, of PricewaterhouseCoopers in Baku, describes the transfer pricing documentation environment in Azerbaijan March 13, 2008
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Irish government refuses to comment on reasons for new negotiation March 13, 2008
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Stuart Simons and Sangravee Thaidamri of Deloitte's transfer pricing team in Bangkok report on the transfer pricing documentation rules in Thailand March 11, 2008
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Monique van Herksen, a principal in Baker & McKenzie in Amsterdam, outlines the Dutch approach to transfer pricing documentation March 10, 2008
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Todd Miller and Michael Friedman, of McMillan Binch Mendelsohn, describe the Canadian transfer pricing documentation environment March 10, 2008
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Carlos Borba, Gonzalo Lucas and Alejandra Barrancos, of Deloitte in Montevideo, report that transfer pricing law has been introduced but no implementing regulations have been yet published March 06, 2008
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Katherine Pinzón, transfer pricing partner in Caracas for Ernst & Young, describes the Venezuelan government’s approach to transfer pricing documentation March 04, 2008
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Union government signs with Luxembourg and completes negotiation with Cyprus March 03, 2008
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Jacques van Rhyn, of PwC in South Africa, describes the policy of the South African Revenue Service (SARS) on transfer pricing documentation March 03, 2008
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Dunja Hitrec, of Ernst & Young in Zagreb, gives a detailed assessment of Croatia's transfer pricing documentation rules March 01, 2008
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The transfer pricing documentation rules were revised in 2007. Lucijan Klemencic, of Ernst & Young, reports from Ljubljana March 01, 2008
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Key development of island's transfer pricing regime expected in 2008 February 29, 2008
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Mike Ahern and Sebastian Lebda, of PwC in Poland, summarise the Polish transfer pricing documentation rules February 27, 2008
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Maarten Koper and Susanne Verloove, of Ernst & Young in Cyprus, discuss the regime for transfer pricing documentation
February 26, 2008
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Davide Bergami and Gianluca Nieddu, of Ernst & Young in Italy, outline the Italian transfer pricing documentation rules February 26, 2008
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Katarina Kuuskoski and Bo Lindqvist of Baker & McKenzie in Stockholm give a detailed account of the documentation environment in Sweden February 25, 2008
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Libor Frýzek and Jiří Teichmann, of Ernst & Young in Prague, describe the environment for transfer pricing documentation in the Czech Republic February 22, 2008
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Fred Burke, managing partner and Thanh Vinh Nguyen, associate of Baker & McKenzie, Ho Chi Minh City, summarise the 2005 rules February 21, 2008
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Comprehensive order issued this week to implement documents law February 21, 2008
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John Nash, chief adviser to the NZ Inland Revenue Department, describes the experience since the guidelines were introduced February 19, 2008
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Leslie Prescott-Haar, of Ernst & Young, outlines the approach to transfer pricing documentation requirements in New Zealand February 19, 2008
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Rajan Sachdev, executive director of transfer pricing at KPMG in India, outlines transfer pricing documentation rules in India February 15, 2008
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Mirror reporting by foreign enterprises mandatory February 15, 2008
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Mario Ortega Calle, of TP Week correspondent Garrigues, explains how the regulation of intra-group expenses has changed February 13, 2008
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Philip Muema, of KPMG in Kenya, outlines the documentation rules in Kenya February 13, 2008
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Joan Hortalà and Neus Mollera from Cuatrecasas Abogados set out key changes to transfer pricing and explain how they impact policy on documentation February 12, 2008
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Caribbean state confirms OECD principles in law. Brian Hanney reports on a move to documents rules February 07, 2008
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Bob Reynolds reports on new treaties finalised by Australia, Japan, Pakistan, India, Russia and Mexico February 07, 2008
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Hardev Singh and Saurabh Dhanuka, of TP Week correspondent KPMG, report on the tribunal’s analysis of transfer pricing approaches February 06, 2008
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Andreas Köster-Böckenförde , of Jones Day in Frankfurt, explains the thinking behind recent revisions to TP law February 05, 2008
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Supplied by Jorge E Castellon and Ramiro Bravo, Ernst & Young Mexico February 03, 2008
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Supplied by TP Week correspondent Kim & Chang. Report by TY Nam and Stefan Moller February 01, 2008
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It will reform transfer pricing agreements, report DJ Yeo and Stefan Moller of TP Week correspondent Kim & Chang January 31, 2008
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Paul Welch and Fletch Heinemann, of Baker & McKenzie, provide a guide to the legal structure for transfer pricing documentation. Additional reporting from DLA Piper January 31, 2008
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Cyril Maucour and Marc Bénard, of Baker & McKenzie in Paris, outline the regime for transfer pricing documentation. Additional reporting by by DLA Piper January 31, 2008
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Provided by DLA Piper January 31, 2008
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Supplied by DLA Piper January 31, 2008
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Provided by DLA Piper January 31, 2008
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Supplied by TP Week correspondent DLA Piper January 31, 2008
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January 31, 2008
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TP Week correspondent Machado Associados reports on a key ruling by the Brazilian tax authorities January 24, 2008
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TP specialists forecast multiple adjustments in the wake of new rules January 19, 2008
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PricewaterhouseCoopers interprets recently updated rules January 19, 2008
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Nick Houseman, Bill Yohana and Geoffrey Morris of PricewaterhouseCoopers Australia examine the implications of a new determination January 16, 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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Rohan Phatarphekar and A Pradeep from TP Week correspondent firm KPMG in India report on two recent cases January 09, 2008
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TP Week correspondent DJ Yeo, of Kim & Chang, explains recent changes to thin capitalisation rules in Korea January 07, 2008
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UK tax authority introduces plan to cut decision times January 07, 2008
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TP Week correspondent DJ Yeo of Kim & Chang reports on the introduction of a new customs APA scheme January 03, 2008
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Pre Budget wish list calls for exemption on TP issues January 03, 2008
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Deloitte in Turkey reports on key developments in Turkey’s transfer pricing policy January 03, 2008
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TP Week correspondent DJ Yeo of Kim & Chang reports on changes to Korea’s thin capitalisation rules December 27, 2007
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Deloitte in China discusses the fundamental issues for multinationals December 27, 2007
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Deloitte UK analyses the HMRC’s statement of practice on advance thin capitalisation agreements. Michael Gordon-Brown and Ian Clarke report December 19, 2007
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Changes will broaden the base of the thin capitalisation regime December 15, 2007
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TP Week correspondent KPMG explains the Delhi Tax Tribunal ruling on Rolls Royce December 13, 2007
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New TP rules to implement Enterprise Income Tax Law add further burdens to multinationals December 12, 2007
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John Nash, chief adviser to New Zealand’s Inland Revenue, writes exclusively on its transfer pricing policy December 11, 2007
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Politicians and lobbyists are calling for tougher transfer pricing rules – especially in the oil sector – in the Philippines. December 11, 2007
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UK revenue issues statement of practice and model agreement December 06, 2007
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Italy’s tough TP policy encourages more corporate deals. PwC reports December 05, 2007
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TP Week sponsor KPMG India comments on two key technical developments December 04, 2007
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Key government inquiry identifies significant weaknesses in TP policy November 29, 2007
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A new agreement finalised yesterday seeks to put an end to money laundering in Fiji by international companies abusing TP rules November 29, 2007
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In a key development, the Indian tax authority reponds to pressure from business November 28, 2007
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The Federal Board of Revenue announces task force to strengthen transfer pricing rules November 28, 2007
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In an exclusive article, Todd Miller and Michael Friedman, of McMillan Binch Mendelsohn in Toronto, analyse the transfer pricing implications of the protocol November 22, 2007
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Tax authority focuses on audits and APAs, reports PwC November 22, 2007
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Restructurings, intangibles, tp methods and comparability dominate OECD transfer prcing agenda November 19, 2007
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The Chinese and the Korean tax authorities have signed their first bilateral advance pricing agreement (APA) November 13, 2007
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The Israeli tax authorities have published a form for the reporting of cross-border transactions. November 01, 2007
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The Income Tax department says Indian companies can enjoy same benefits as US companies November 01, 2007
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The Taiwanese finance ministry issued new guidelines for advance pricing agreements (APAs) at the end of September. Deloitte partners Eunice Kuo and Lucia Tung report from Taipei October 22, 2007
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Rosa Maria Soares, transfer pricing partner at Deloitte in Lisbon, describes plans for advance pricing agreements in Portugal October 19, 2007
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Substantial changes to the Russian transfer pricing regime will be debated by parliament in late November. October 18, 2007
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Theo Elshof and Pim Gerritsen van der Hoop, of Deloitte in the Netherlands, writing exclusively for TP Week, examine the TP priorities for the Dutch tax authorities October 17, 2007
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The government has announced a series of key changes to transfer pricing rules which take effect on January 1 2008. October 17, 2007
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By Rainer Eidemiller and Priit Lätt of Glimstedt Straus & Partners in Tallinn writing exclusively for TP Week October 12, 2007
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Hardev Singh, senior manager in the transfer pricing department at KPMG India, looks at the efforts of income tax and customs departments to achieve consistency from multinationals. October 09, 2007
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Luis Eduardo Ocando, for E&Y in Panama City, comments on new regulations for transfer pricing October 08, 2007
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Sponsored Americas piece by Alan Granwell and Eric Ryan of DLA Piper US September 28, 2007
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Manuel Bouzas of Garrigues in Spain reports on new transfer pricing regulations in Spain September 27, 2007
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Gabriela Villavicencio and Armando Cabrera, of Baker & McKenzie, look how Argentina's transfer pricing rules have developed since their introduction in 1998 September 27, 2007
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Simone Dias Musa and Clarissa Machado, of Baker & McKenzie, detail the development of the transfer pricing regime in Brazil and point out its peculiarities September 27, 2007
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By Gianni De Robertis (Italy), Sean Foley (US), Jaap Reyneveld (The Netherlands), Sergio Schuindt (Brazil) and Tomoko Wada (Japan) of KPMG September 27, 2007
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By Anders Bjørn (Denmark), Henrik Lund (Denmark/The Netherlands) and Steven Tseng (China) of KPMG September 27, 2007
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Stephan Rasch and Susanne Hammerschmitt of Deloitte Germany report on the transfer pricing implications of the jurisdiction's corporate tax reform law September 27, 2007
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Peter Oszkó and Annamária Kőszegi of Deloitte in Budapest report on how the tax authorities have become tougher September 27, 2007
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HMRC seeks the view of big business on its transfer pricing recommendations September 27, 2007