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Komatsu, a Japanese construction equipment manufacturer, announced today that it is being investigated by the Japanese tax authorities over transfer pricing concerns. March 11, 2010
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A Japanese multinational announced today that the Japanese and Singapore tax authorities had negotiated a bilateral advance pricing arrangement relating to the company’s Singapore operations. March 10, 2010
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China has released a circular that drastically changes the tax rules for foreign companies deriving income through establishments in China. March 10, 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 discuss why Japan continues one of the most challenging jurisdictions for tax and transfer pricing in the world. March 09, 2010
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An Indian authority has ruled that the assignment of rights and obligations is not taxable in India in the absence of a permanent establishment (PE). March 05, 2010
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Ken Okawara, Yukiko Komori, Satoko Kawamura, and Koji Oshima of Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) review the Japanese documentation situation.
March 01, 2010
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Three new dispute resolution panels have been set up in Mumbai, New Delhi and Hyderabad to ease the burden of dealing with taxpayers’ applications for resolutions. February 26, 2010
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The Mumbai Income Tax Appellate Tribunal has ruled that when determining the arm’s-length price of an international transaction, transfer pricing officers (TPO) must apply transfer pricing methods in accordance with the manner in which they are prescribed in the country’s transfer pricing rules. February 25, 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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India’s finance minister has told a conference of tax officials and taxpayers that transfer pricing must play a “special role” if India is to establish itself as a leading global economy. February 22, 2010
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Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore. February 22, 2010
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Australia will introduce new tax agent services legislation on March 1 which includes information about safe harbour rules. February 17, 2010
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The Institute of Chartered Accountants of India (ICAI) is planning to help its members, especially smaller auditing firms, get information on international transfer pricing methods and systems, so they can take on larger audit assignments for companies that have overseas businesses. February 17, 2010
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An Indian tax tribunal has ruled that an arm’s-length payment by a non-resident to its India permanent establishment absolves the non-resident from any additional tax liability. February 17, 2010
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Phoenix Technologies has seen a bigger than expected revenue increase in the first three months of its financial year after settling a dispute with the Taiwan National Tax Administration (TNTA). February 17, 2010
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Hasnain Shroff and Poonam Ghelani in India look at the important VVF Limited case. February 16, 2010
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Taxpayers in China need to urgently complete transfer pricing documentation, or face the wrath of the State Administration of Taxation. February 10, 2010
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The Delhi bench of the Income-tax Appellate Tribunal held that interest-free loans advanced by Indian companies to their foreign affiliates do not comply with the arm’s-length standard. February 10, 2010
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Taiwan has released new assessment rules on the applicability of double taxation agreements that will affect permanent establishments in the country. February 10, 2010
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The special bench of Chandigarh Income Tax Appellate Tribunal has restated the critical importance of conducting a detailed FAR analysis. February 04, 2010
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Indonesia’s head of transfer pricing has told a seminar of tax professionals the criteria used for initiating an audit, amid increased scrutiny from the country’s tax authorities. February 03, 2010
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Hasnain Shroff, A Pradeep and Vinita Chakrabarti of KPMG India discuss taxpayers' relief over finding out that the use of the new Indian dispute resolution mechanism is optional. February 02, 2010
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Ceteris, a global economic consulting firm, has hired a partner of Ernst & Young to set up its transfer pricing practice in New Zealand. February 02, 2010
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The Indian government has finally confirmed that the country’s new dispute resolution panel is not mandatory, contrary to what taxpayers were led to believe. January 29, 2010
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Hasnain Shroff and Vinita Chakrabarti of KPMG in India look at the Global Vantedge case. January 27, 2010
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Changes to Taiwan’s tax law mean that gains from structured notes are no longer regarded as interest income and so should be liable for withholding tax. January 18, 2010
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The introduction of safe harbour rules in India came one step closer this week with the establishment of a committee that will finalise details of the new provision. January 13, 2010
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The Singapore government has passed a law that requires taxpayers to comply with the arm’s-length principle. January 13, 2010
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In a recent ruling in the case of Gharda Chemicals Limited, interesting questions were raised before the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT), the second appellate and the last fact finding authority in Indian judiciary. 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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A recent Indian tribunal ruling has emphasised the importance of using comparable data for the purpose of benchmarking controlled transactions. January 06, 2010
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The Indian government has issued Press Note number 8, modifying the foreign technology agreement/collaboration policy wherein all payments towards royalties, lump-sum fees for transfer of technology and payments for the use of trademarks or brand names will be allowed to be paid without any restrictions.
January 04, 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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The release of Hong Kong’s newest practice note on transfer pricing has been widely welcomed by taxpayers, but concerns have been raised over its lack of clarity. December 10, 2009
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The Indian tax authority has sent two senior tax officials to Mauritius and Singapore to ensure that tax treaty arrangements are being maintained. December 10, 2009
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The Indonesian Tax Office (ITO or DGT) is proactively approaching taxpayers and requiring them to answer queries and questionnaires. December 10, 2009
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On Friday, the Hong Kong Inland Revenue Department (IRD) released Departmental Interpretation a Practice Note (DIPN) 46, establishing the tax authority’s interpretation and practices on transfer pricing methodologies and related issues. December 07, 2009
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India’s new dispute resolution mechanism has not got off to a good start. December 02, 2009
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The Indonesian government could reverse a key plank of its coal policy that was put in place to deal with transfer pricing abuses. December 02, 2009
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KPMG took the top award for transfer pricing at International Tax Review’s Asia Tax Awards in Singapore last Tuesday 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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The Indian Central Board of Direct Taxes (CBDT) has finally unveiled rules for the country’s new dispute resolution panels (DRP), nearly two months after the mechanism became effective. Samir Gandhi and Vineet Chhabra of Deloitte India discuss the rules notified by the CBDT. November 25, 2009
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The introduction of safe harbour rules to India is a “double-edged sword” and the tax authorities need to be careful with how they implement them, says a report. November 19, 2009
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Loss making companies, those with strange profit patterns or with a large amount of related party transactions are the key targets of audits in China, according to leading advisers. November 19, 2009
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Vispi Patel has left his role as head of direct tax at Economic Laws Practice in Mumbai November 18, 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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Deal reduces the technology company’s tax bill for the fiscal years 2000 to 2006 by $5.2 million. November 17, 2009
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True Partners Consulting International network, an association of tax consulting firms in select markets around the world, has added three new affiliates. November 17, 2009
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The Chinese tax authorities have concluded their first bilateral advance pricing arrangement (BAPA) with a European country November 04, 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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Samir Gandhi and Manisha Gupta of Deloitte India explain the importance of recent controversy for taxpayers dealing with issues involving section 40A of the 1961 Income Tax Act. November 04, 2009
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The number of completed advance pricing agreements (APA) has risen in Korea, according to figures released by the country’s tax authority. October 29, 2009
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Samir Gandhi, Manisha Gupta and Viswanathan Subramaniam of Deloitte India explain the importance of maintaining appropriate documentation to evidence that the transaction price has been computed in good faith and with due diligence. October 29, 2009
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Information and guidelines on India’s new alternate dispute resolution mechanism has been pushed back once again, amid growing uncertainty from the country’s tax professionals. October 29, 2009
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The Taiwan Ministry of Finance recently introduced guidelines for the determination of Taiwan source income. October 29, 2009
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Karl Gruendel and Ralf Heussner of Ernst & Young Shinnihon Tax explain the difficulties facing taxpayers with operations in Japan as the government struggles to find revenue sources. October 29, 2009
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The number of advance pricing arrangements (APAs) has dropped in Australia, figures from the country’s tax authorities have revealed October 21, 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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The introduction of India’s new dispute resolution mechanism will reduce the amount of revenue generated through transfer pricing assessments, says a leading transfer pricing specialist October 14, 2009
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The country aims to create a benchmark for coal prices which would help with pricing exports and put an end to transfer pricing abuses October 06, 2009
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The threat of taking a transfer pricing dispute to court is a good bargaining tool for taxpayers in developing countries, a panel of transfer pricing specialists has said September 29, 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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The Chinese State Administration of Taxation (SAT) hosted an important national training session focused on the pharmaceutical industry for over 100 transfer pricing officials across the country this week September 17, 2009
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India’s new dispute resolution panel is proving to be a popular choice with the country’s highest court, though the mechanism does not become effective for another two weeks September 16, 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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The number of transfer pricing audits in Malaysia is set to increase as the country’s tax authority attempts to improve taxpayer compliance 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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Transfer pricing will feature strongly when International Tax Review presents its third annual Asia Tax Awards in Singapore on November 24 September 02, 2009
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What does the introduction of advance pricing arrangements mean for taxpayers in India? September 01, 2009
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In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing. September 01, 2009
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An important concession helpful to manufacturers using mainland China contract processors has been denied. August 19, 2009
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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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The new Direct Taxes Code tabled by the Indian finance minister has proposed some sweeping changes in the area of transfer pricing, explain Rohan Phatarphekar and Hardev Singh August 13, 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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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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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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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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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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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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Tae-Yeon Nam, Dong-Jun Yeo and Stefan Moller, Kim and Chang, Seoul 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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Hardev Singh and Saurabh Dhanuka of KPMG highlight the key changes the Indian Union Budget 2009 makes to the transfer pricing and related provisions of the Income-tax Act, 1961 July 06, 2009
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A ruling by the Pune tribunal says that the revenue authorities in India must clearly demonstrate the appropriateness of a particular method when trying to make an adjustment based on the taxpayer's method choice. Vineet Chhabra and Viswanathan Subramaniam of Deloitte explain. July 02, 2009
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The Australian Tax Office has been given more government money to tackle aggressive schemes as the onslaught on transfer pricing uses continues in the country. July 01, 2009
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We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation? July 01, 2009
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The State Administration of Taxation in China has ordered the provincial and local level tax authorities to initiate a nationally coordinated campaign of tax investigations on operators of highways. June 24, 2009
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The latest rules on special tax adjustments were a hot topic when China’s State Administration of Taxation (SAT) held a half-day online question and answer session earlier this month. June 24, 2009
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Following a recent Indian tribunal ruling on the use of cash profit/sales, Samir Gandhi and Vineet Chhabra of Deloitte India explain the importance of profit level indicators (PLI) under the TNMM. June 24, 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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Michael D’Ascenzo, commissioner of the Australian Tax Office stressed that companies should practice good corporate governance that takes into account tax risks. June 17, 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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A career in transfer pricing has always afforded the luxury of flexibility, with professionals enjoying the opportunity of internal secondments all around the world. Some destinations have traditionally had more appeal than others, with the last five years seeing a particular rise in opportunities to work in Asia. June 16, 2009
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The economic and technological development zone office of the Beijing Municipal State Tax Bureau (BSTB) has signed its first unilateral advanced pricing agreement (APA) after various rounds of negotiations. June 11, 2009
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With India’s budget only three weeks away, tax professionals have come out in support of advance pricing agreements as a means of dealing with transfer pricing disputes. 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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What documentation do I need to prepare and file by what time for entities in Taiwan? 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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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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My company has entities in South Korea. What are the documentation requirements for those entities? 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 panellists bemoaned the documentation burden during the transfer pricing session at International Tax Review’s fourth annual Asia Tax Executives’ Forum in Singapore last week May 21, 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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Michael Velten, Angie Ng and Penelope Wong move on from Transfer Pricing Associates in Asia. May 18, 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 State Administration of Tax (SAT) in China has released two key circulars with important implications for transfer pricing investigation and follow-up measures. May 13, 2009
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The Australian Taxation Office has issued a new interpretative decision that highlights important tax issues facing foreign resident taxpayers leasing substantial equipment in Australia. 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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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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In India, the advance ruling in the case of Canoro Resources addresses the applicability of domestic anti-avoidance provisions to transfers between partners and foreign partnerships. April 29, 2009
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A recent court ruling has determined that disputes dealing with the attribution of profits to permanent establishments in India should not be heard by the high court, as the country’s tribunals will have the final say on the matter April 29, 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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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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An Indian tax tribunal has ordered a Belgian drug company to rethink its transfer pricing methods for transactions with its Indian subsidiary, despite referring the case back to the transfer pricing officer. April 08, 2009
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Hiroyuki Takahashi has joined KPMG as a director in the firm’s global transfer pricing services practice. Takahashi will be based in Shanghai.
April 06, 2009
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An Indian tax tribunal has said a taxpayer may have to change costs and profits on account of differences which arise in comparability analysis, but still referred the case back to a transfer pricing officer April 01, 2009
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Multinationals should reassess their advanced pricing agreements as the economic downturn puts pressure on existing transfer pricing models April 01, 2009
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Mimi Lau has joined Transfer Pricing Associates as a consultant in its Hong Kong office, though she will also advise on global projects April 01, 2009
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A lack of coordination between Vietnam’s two transfer pricing authorities is leading to companies failing to maintain the relevant documentation
March 25, 2009
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The global economic downturn is putting corporate officers under extreme pressure. March 19, 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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Japan remains one of the most challenging tax jurisdictions, with transfer pricing enforcement being a focal point of the Japanese tax authorities. Both foreign and Japanese multinationals face increasing scrutiny and a heightened risk of transfer pricing audits and potential adjustments, explain Karl Gruendel and Rolf Heussner of Ernst & Young Shinnihon Tax. March 16, 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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An Indian automotive company has lost its appeal against the Indian transfer pricing authorities over the method used for carrying out transactions with its various entities. February 25, 2009
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A tribunal in India has ruled that payment of the arm’s length price to a dependent agent does not remove the tax liability of a foreign entities’ permanent establishment in India. February 25, 2009
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The head of the organisation that represents the information technology-business process outsourcing industry in India has called on the government to introduce more generous transfer pricing rules February 19, 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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Tax professionals in Australia agree with the authorities’ view of the value of the Administrative Appeals Tribunal’s judgement in the Roche Products case, though some would have preferred a more comprehensive ruling from the AAT February 11, 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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The Indian division of Bunge, a US food company, has been ordered to pay additional taxes due to a transfer pricing-related indiscretion. The Indian income tax authority has said the company may also face a penalty for concealment of income January 27, 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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Steven Tseng and Chi Cheng, KPMG China
January 21, 2009
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Glenn DeSouza says China’s transfer pricing regulations are a good sign of economic development 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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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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An important decision by the High Court orders transfer pricing offices to conduct new assessments for several taxpayers. January 09, 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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An Indian court has ruled that Coca-Cola India failed to apply transfer pricing rules following an agreement to offer advisory services to a related party. January 07, 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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KPMG’s global transfer pricing services practice transfers two key figures and hires another to the China team. January 06, 2009
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Transfer Pricing Associates (TPA) has appointed Michael Velten to its Asia team. Velten will lead the firm's global financial services practice and will be based in Hong Kong 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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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 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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Advanced pricing arrangement programmes in Australia are expected to increase next year as taxpayers look for more certainty and the tax office enhances its transfer pricing review and enforcement activity December 03, 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 has long been an area of focus for the Australian Taxation Office. The ATO recently issued a taxpayer alert advising taxpayers that shifting of business losses into Australia will be under increased scrutiny 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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Countries in South-East Asia are introducing or reforming their transfer pricing rules to increase revenues and attract foreign investment 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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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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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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The addition of Hiroaki Furuya to Gardere’s international tax and transfer pricing (ITTP) practice strengthens an already robust team October 28, 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 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 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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NERA Economic Consulting opens Beijing office
October 14, 2008
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KPMG’s global transfer pricing services group in China is expanding with a series of new hires which will take its total number of full time professionals to more than 100 October 08, 2008
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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
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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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KR Girish and Hardev Singh of www.tpweek.com correspondents, KPMG, reveal why the Delhi Tax Tribunal sided with the taxpayer in a critical dispute over India’s safe harbour provisions September 25, 2008
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Malaysian taxpayers will soon be able to apply for advance pricing arrangements September 04, 2008
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Winnie Di and Cecilia Lee have become partners of PricewaterhouseCoopers's transfer pricing practice in Asia August 28, 2008
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The Bombay High Court has ruled that payment of arm’s length remuneration to a Dependent Agent Permanent Establishment (DAPE) in India extinguishes the tax liability of the foreign enterprise August 28, 2008
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Uday Ved has been appointed head of tax at KPMG India. Ved joined the firm in 2006 from RSM & Co where he was a partner and head of tax.
August 20, 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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Stuart Edwards of PricewaterhouseCoopers, Australia, believes courts will favour traditional transactional transfer pricing methods rather than bottom line profits methods in the wake of the landmark Roche decision. July 30, 2008
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Steven Tseng, and George Bradt, of KPMG China, discuss the highly anticipated changes to China’s transfer pricing regulations July 30, 2008
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Karishma Popat and Fatema Hunaid from Grant Thornton India, identify recent developments in audits in the pharmaceutical industry transfer pricing audit in India July 30, 2008
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The Australian Taxation Office has issued a discussion paper on thin capitalisation to its National Tax Liaison Group Transfer Pricing subgroup July 24, 2008
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Gustavo Haddad and Bruno Carramaschi,of Lefosse Advogados in cooperation with Linklaters, explain what Brazil’s authorities have done to update rules on dealing with tax havens July 17, 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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KR Girish and Hardev Singh, of TP Week correspondent KPMG in India, report that tribunal relied on Mentor Graphics decision June 23, 2008
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Transfer pricing at the heart of alleged state losses of $63 million June 12, 2008
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New regulations implement 2006 Income Tax law June 12, 2008
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Two partners move to UAE to cover the Gulf June 12, 2008
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K R Girish and Rohit Jain, of TP Week India correspondent KPMG, report that slow and ineffective resolution of tax disputes has led to a growth in MAP June 11, 2008
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Tax authority says it will concentrate on intangibles and restructuring June 02, 2008
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TP Week correspondent KPMG explains the thinking behind the recent Foster’s case in before the Authority for Advance Rulings in India 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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Philippines Bureau of Internal Revenue plans new revenue regulations May 23, 2008
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Rulings authority declares beer company must pay tax in India May 22, 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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New communiqué gives taxpayers more time to file report April 28, 2008
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Five years of profits with Chinese joint venture company under scrutiny April 25, 2008
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Cargill case in India puts limits on scope of transfer pricing officers April 23, 2008
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Takashimaya hits transfer pricing troubles over Singapore business April 21, 2008
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Hardev Singh and Kishore Nair, of TP Week correspondent KPMG in India, say that further litigation is expected April 18, 2008
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Move quadruples transfer pricing expertise across sub-continent April 17, 2008
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Indian government is more focused on general election, say local commentators April 10, 2008
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Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit April 06, 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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Commissioner revises tax bill on software licence earnings from 1999 to 2005 in groundbreaking ruling April 03, 2008
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H Ching Tan and Douglas Fone, of Transfer Pricing Associates, examine the transfer pricing issues in funding for Chinese enterprises March 25, 2008
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Ernst & Young in Israel explains how companies deal with form 1385 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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Government seeks more resilient position on assessments 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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Pharmaceuticals company challenges tribunal ruling on transfer pricing February 29, 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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John Nash, chief adviser to the New Zealand Inland Revenue, analyses the lessons from recent cross-border restructurings February 20, 2008
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Kishore Nair, of TP Week correspondent KPMG, reports that 72% of TNMM cases are selected for audit February 19, 2008
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KR Girish and Himanshu Patel, of KPMG, explain why high profile legal cases provoke a change in the law 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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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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TP Week correspondent backs comprehensive changes to the transfer pricing rules in pre-Budget submission February 18, 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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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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Government announces TP is among key reasons for inquiry 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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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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Company agrees to $5 million bond to allow export of latest consignment January 24, 2008
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China's State Administration of Taxation reports revenue up 45% January 17, 2008
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DJ Yeo, Stefan Moller and TY Nam, of TP Week correspondent Kim & Chang outline the thinking behind Korea’s TP policy January 16, 2008
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Bottled water company clashes with Pacific nation revenue authority over $3 million a week in exports January 13, 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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KPMG, TP Week’s correspondent in India, comments on why TNMM is the preferred TP methodology in India. Hardev Singh reports 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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Pre Budget wish list calls for exemption on TP issues January 03, 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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Deloitte in China discusses the fundamental issues for multinationals December 27, 2007
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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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India’s leading software trade body supports early move December 18, 2007
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The report, Tax Risks in India, reveals fears about inconsistent rules and rulings December 14, 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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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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Indian consultancies are facing a major shortage of transfer pricing specialists. December 11, 2007
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Carpet manufacturer Feltex collapses amid claims it is New Zealand’s Enron December 05, 2007
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E&Y TP senior partner Okawara to lead new team December 04, 2007
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TP Week sponsor KPMG India comments on two key technical developments December 04, 2007
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TP Week sponsor KPMG reports exclusively from a meeting with the revenue body and the Big Four. KR Girish and Veena Parrikar write December 03, 2007
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In the first of a series, Carol Todd of KPMG New Zealand, looks at customs valuation in her home country 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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The Chinese and the Korean tax authorities have signed their first bilateral advance pricing agreement (APA) November 13, 2007
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Bob Reynolds reports on the explosive growth in transfer pricing for intangibles in Asia Pacific November 08, 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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KR Girish and Rohit Jain, of KPMG in South India, review the Supreme Court verdict in Morgan Stanley November 08, 2007
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Income Tax Department appeals decision on captive November 08, 2007
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Bob Reynolds reports on a case which will have widespread implications for companies November 08, 2007
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Three of the 57 new partners admitted by PwC in China and Hong Kong are transfer pricing specialists. They are among 11 new tax partners. November 04, 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 number of mutual agreement procedures (MAP) involving an advance pricing agreement (APA) in Japan has increased by 600% in the last decade. October 29, 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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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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Global law firm forms alliance with Transfer Pricing Management Consulting October 15, 2007
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A more aggressive approach by China's tax authorities will be unleashed by new law. Bob Reynolds, TP Week, reports 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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SS Palwe, Samir Gandhi, Tehmina Latiwala and Mital Patel of Deloitte in Mumbai comment on a key transfer pricing ruling October 08, 2007
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K R Girish and Veena Parrikar, of KPMG, question one solution fits all for companies seeking transfer pricing savings from shifting activities offshore October 08, 2007
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Australian bank could be scrutinised over growth in business in Valetta September 27, 2007
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Sponsored India report from Rohan Phatarphekar and Hardev Singh of KPMG India September 27, 2007
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KR Girish and Rohit Jain, of KPMG in South India, review the impact of key transfer pricing decisions for multinational companies September 19, 2007