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International Tax Review has compiled a special free pdf report on Vodafone’s Indian Supreme Court victory. View the ruling, read what industry had to say, and uncover what this decision means for your business. January 30, 2012
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While Vodafone secured a historic victory in the Supreme Court of India last week, there is still the issue of an Rs8,500 crore ($1.7 billion) transfer pricing order from the Income Tax Department. January 24, 2012
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The Hong Kong Inland Revenue Department (IRD) will launch an advance pricing agreement (APA) programme in April. January 09, 2012
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The outline for Japanese tax reform proposals was released on December 26 2011 with changes to intercompany loan regulations. January 06, 2012
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A recent ruling by the Tax Tribunal of Korea said companies that make transfer pricing adjustments after reporting importation to customs will not be refunded. January 05, 2012
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The decision on intercompany debt funding has been made by the New Zealand High Court in Alesco New Zealand Ltd v CIR. January 03, 2012
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China has underlined its determination to strengthen its anti-avoidance rules by concluding the country’s first thin capitalisation audit. January 03, 2012
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The Indonesian government has introduced a number of changes to its transfer pricing regime that will affect the way taxpayers apply the arm’s-length principle on related party transactions. December 13, 2011
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Petra Foods, an Indonesian taxpayer, has referred to previous payments for a transfer pricing adjustment as recoverable in its third-quarter 2011 statement, meaning it expects to win its dispute with the Indonesian Tax Office. November 24, 2011
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Takeda Pharmaceuticals has announced that its mutual agreement procedure (MAP) with the National Tax Agency in Japan did not result in an agreement with the US. November 22, 2011
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This year’s final figure of Rs44,500 crore ($8.9 billion) for transfer pricing adjustments in India is more than double last year’s total. November 14, 2011
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Australia has released a consultation paper aiming to bring its transfer pricing regulations more in-line with international best practice, following the Revenue’s defeat in the SNF case earlier this year. November 03, 2011
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The Indian government has said guarantee fees, paid by Indian companies in the acquisition of foreign assets, fall into the income tax net because they are a cost to the company. November 02, 2011
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The Japanese and Australian competent authorities held a seminar last week to discuss a more streamlined approach to bilateral advance pricing agreements (APA) between the two countries. October 19, 2011
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The Australian Taxation Office (ATO) has released proposals, for consultation, for a new international dealings schedule (IDS), to replace the schedule 25a and thin capitalisation forms. October 19, 2011
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The Indian transfer pricing authorities have no right to question the commercial wisdom of the taxpayer in incurring expenditure for business conduct, the Mumbai Income Tax Appellate Tribunal has ruled. October 05, 2011
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Australia’s proposed Minerals Resource Rent Tax (MRRT) poses transfer pricing problems for taxpayers with all but the simplest transactions, adding to the uncertainty surrounding the tax. October 05, 2011
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Gagan Kumar of Archer & Angel explains the intricacies of the Diageo India case.
October 04, 2011
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China’s State Administration of Taxation has clarified a number of issues relating to the administration of foreign companies that are controlled by Chinese investors. October 03, 2011
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China’s State Administration of Taxation (SAT) has released information on how taxpayers should prepare and complete contemporaneous transfer pricing documentation for the coming year. September 28, 2011
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Taxpayers in the emerging BRIC economies need to be aware that face-to-face interaction with officials will reduce the length of transfer pricing disputes, says panel. September 27, 2011
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A New Zealand court case involving debt finance is creating waves because it seems the Inland Revenue Department (IRD) is contradicting its own guidelines. September 16, 2011
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By Qisheng Yu, Amy Cai and Wing Siu, PwC China September 15, 2011
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The Vietnamese tax authorities have released a mid-year statement indicating that reported revenue loss has decreased by $100 million. September 14, 2011
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The transfer pricing spotlight has now fallen on IT companies in India, with claims that foreign firms are booking less profit than their domestic rivals. September 14, 2011
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RN Dash, the Indian director general of income tax, spoke about the country’s efforts in transfer pricing today at International Tax Review’s India Tax Forum in Delhi.
September 07, 2011
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The transfer pricing panel at International Tax Review’s India Tax Forum covered a range of issues affecting Indian taxpayers, with practical advice and experiences given.
September 07, 2011
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An industry body has exclusively revealed to TPWeek that the Vietnamese government will introduce an advance pricing agreement (APA) programme in its tax code. August 25, 2011
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The case of Symantec Software Solutions Pvt Ltd, heard before the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), has implications for the application of transfer pricing provisions, which continue to differ from global best practice.
August 17, 2011
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August 11, 2011
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Next year will herald a widescale period of change for tax in India. It will force tax directors from domestic and international companies to completely reconsider their strategies and to seek efficiencies at all levels of their company's tax affairs.
August 10, 2011
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The lack of clarity in part of a new transfer pricing form issued by Malaysia’s tax authorities will create some difficulties and pitfalls for taxpayers. July 27, 2011
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The Delhi Tribunal, in the case of CRM Services, a call centre provider, has passed a relevant ruling for captive IT enabled or business process outsourcing (BPO) service providers. July 27, 2011
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By Peerapat Poshyanonda and Alisa Arechawapongsawat of PwC Thailand July 26, 2011
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By SM Thanneermalai and Anushia Soosaipillai of PwC Malaysia July 25, 2011
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Bangladesh’s National Board of Revenue intends to check irregular transfers of funds in a bid to reduce the estimated $35 billion revenue loss attributed to transfer pricing. July 20, 2011
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The Ho Chi Minh City Tax Department in Vietnam has promised to investigate global companies who claim to make consistent losses in the country. July 20, 2011
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Japan’s transfer pricing legislation was revised on June 30 2011 to introduce the most appropriate method rule, rather than the hierarchy system, which is now abolished. July 20, 2011
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The Australian Taxation Office (ATO) is targeting foreign companies that shift profits offshore to reduce their local tax liability. The application of transfer pricing rules will be reviewed.
July 13, 2011
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Taxpayers in China transferring equity interests in Chinese companies are being advised to conduct appraisals to determine the fair market value of the transferred interest. July 13, 2011
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Taxpayers need to examine and evaluate the comparable studies they plan to use in China after a transfer pricing adjustment grabbed the headlines. July 07, 2011
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In a new ruling, the Australian Tax Office (ATO) has set out how it expects business structuring for multinational enterprises to be documented for transfer pricing purposes. July 06, 2011
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The Australian Tax Office (ATO) will not appeal the Full Federal Court decision on comparables, which ruled in favour of the taxpayer, SNF, as the 28-day leave for the Commissioner to seek appeal has now passed. July 01, 2011
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By Cecilia Lee, Colin Farrell, Rhett Liu, David Smith and Deborah Li of PwC Hong Kong.
June 24, 2011
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The proposed Mineral Resource Rent Tax (MRRT) will require the use of domestic transfer pricing, an exposure draft revealed. June 22, 2011
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India and the OECD have announced plans for a three-year partnership to strengthen cooperation and provide greater opportunities for structured dialogue and information sharing. June 22, 2011
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By Nicole Fung and Michael Nixon, PwC Singapore June 20, 2011
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Pranab Mukherjee, India’s finance minister, said transfer pricing is robbing developing nations of scarce natural resources.
June 15, 2011
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Chinese tax authorities are giving financial institutions a deadline of only one to two weeks, rather than 20 days, to submit transfer pricing documentation for the 2008 and 2009 financial years.
June 13, 2011
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The Australian Tax Office (ATO) has lost its appeal against the taxpayer, SNF, at the Full Federal Court in a transfer pricing case concerning comparables and method application. June 08, 2011
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June 02, 2011
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The Chinese State Administration of Taxation (SAT) has broadened its audit focus and will pay more attention to intangibles, controlled foreign companies (CFC) and thin capitalisation. June 01, 2011
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The draft reportable tax position (RTP) schedule, effective July 1 2011, will require some corporate taxpayers to disclose information regarding reportable tax positions as a supplement to their annual income tax return, bringing more uncertainty for transfer pricing arrangements. May 26, 2011
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While addressing a seminar organised by the Associated Chambers of Commerce and Industry of India, on May 12 2011, R N Dash, the director general of international tax, said transfer pricing cases shall now be subject to audit by the comptroller and auditor general (AG) of India. May 20, 2011
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By Henry An and Wonyeob Chon of Samil PwC May 18, 2011
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The permanent establishment (PE) panel at International Tax Review’s Asia Tax Executives’ Forum in Singapore last week discussed the movement of employees and to what extent this could constitute a PE. May 18, 2011
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On March 11, Japan was rocked by the most powerful earthquake it has ever recorded. But, following the devastation, wrought by the aftershocks and tsunami, the fallout was not just nuclear. The earthquake may have a number of transfer pricing consequences too. May 18, 2011
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Corporate tax executives should translate chapter nine of the OECD’s Transfer Pricing Guidelines into simpler language should be translated by corporate taxpayers so their company's management can better understand them, so said Sharon Tan, senior tax director for Nike in the Asia Pacific region, at the International Tax Review Asia Tax Forum in Singapore today. May 11, 2011
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By Vinita Chakrabarti and Rohan Phatarphekar of KPMG and Waman Kale and A. Pradeep of B S R & Co.
May 10, 2011
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Taxpayers can no longer use companies with segmental results, or those with a comparatively low turnover, as a comparable for benchmarking purposes under transfer pricing provisions in India. May 04, 2011
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The world’s attention has turned to Pakistan after the killing of Osama bin Laden, but companies will be keeping an eye on the country for different reasons as it considers introducing transfer pricing documentation requirements in the upcoming budget. May 04, 2011
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China’s State Administration of Taxation (SAT) has confirmed it initiated 178 transfer pricing investigations in 2010 and concluded the same amount. April 28, 2011
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The Thai Revenue Department (TRD) has issued a questionnaire for taxpayers to provide details of their related-party transactions, increasing the scrutiny they apply to transfer pricing arrangements. April 27, 2011
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By Paul Balkus and Melissa Heath of Ernst & Young April 26, 2011
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A campaign is building for the introduction of the inter-quartile range and the acceptance of multiple-year data for transfer pricing documentation in India – a country that goes against the global best practice. April 26, 2011
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The transfer pricing panel at International Tax Review’s annual Asia Forum in Singapore next month promises to live up to its reputation as one of the most popular panels at the event. April 26, 2011
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Computer company IBM has lost a two-year dispute with the Australian Tax Office (ATO) over royalties paid to its American parent. April 20, 2011
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April 13, 2011
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April 07, 2011
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A decision of the Supreme Court will give taxpayers involved in contentious matters in India the chance to deal with specialists in the future. April 06, 2011
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A UK taxpayer said India is a “totally unreasonable” jurisdiction in which to do business. March 31, 2011
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Two of India’s leading tax officials have warned taxpayers that poor documentation and misleading information will be pounced upon by the tax department. March 30, 2011
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Taiwan has issued draft thin capitalisation guidelines, following the introduction of rules in January. March 28, 2011
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The change to India’s 5% margin, for the determination of the arm’s-length price, made in the recent budget, was intended to simplify the process for taxpayers but it has only created further confusion. March 23, 2011
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The Mumbai Income Tax Tribunal (ITAT) has sent back the file of Teva India, dealing with pharmaceuticals, to the transfer pricing officer (TPO) to reassess whether Vimta Labs, a contract research and testing organisation with abnormally high profit, is comparable to a contract R&D provider. March 22, 2011
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The Australian Tax Office (ATO) released new guidance on its advance pricing agreement (APA) programme last week. March 17, 2011
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When the Indian budget announced that transfer pricing officers’ (TPO) power would be extended to the power of survey, allowing them access to taxpayers’ premises to validate functional analysis, it provoked strong reactions from practitioners. March 15, 2011
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Last week’s budget in India included a boost to the transfer pricing officer’s (TPO) power, allowing them access to a taxpayer’s premises to obtain information about the arm’s length price (ALP) methodology. March 09, 2011
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China poses a number of problems for taxpayers when evaluating the repatriation of profit in the case of intangible assets. March 09, 2011
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The Mumbai Income Tax Appellate Tribunal (ITAT) has ruled that a taxpayer’s past transactions cannot be used as a comparable uncontrolled price (CUP) for the purpose of benchmarking a transaction. March 02, 2011
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Draft legislation on Australia’s controlled foreign company (CFC) rules and the tax treatment of certain foreign income has been released in an attempt to modernise the system. The changes mean tougher transfer pricing enforcement. February 28, 2011
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Li Ying, transfer pricing director at Siemens China, talks to Sophie Ashley about her personal experience with cost
sharing, dealing with the authorities and why China’s attitude to copyright is stopping companies from
transferring their IP to the country. February 22, 2011
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The Indian finance minister’s comments to the press last month about the inadequacies of the country’s transfer pricing norms have provoked a new wave of hope for future clarity, reports a KPMG correspondent. February 18, 2011
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The Delhi Income Tax Appellate Tribunal (ITAT) has ruled that transfer pricing provisions do not apply if the assessee is not subject to tax in India. February 16, 2011
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The assistant director of income tax (ADIT) in Bangalore has rejected the valuation of assets, by a registered valuer, as arbitrary.
February 09, 2011
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The Australian Tax Office has released a tax ruling today on business restructuring. February 08, 2011
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Transfer pricing will be covered by a number of panels at this year's Asia Tax Executives' Forum in Singapore in May February 02, 2011
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Jeff Yuan and Ray Zhu of PwC in Beijing explain how a multinational enterprise and its Chinese subsidiary. set up as a limited function distributor, should deal with a proposed transfer pricing adjustment. February 02, 2011
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The OECD has revealed that Masatsugu Asakawa is to be appointed the new chairman of its Committee on Fiscal Affairs (CFA). January 31, 2011
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A recent transfer pricing dispute in China has reiterated the country’s shift from enforcement and administration towards complex transfer pricing issues and alignment with internationally recognised practices. January 26, 2011
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India’s Finance Minister said yesterday that an upgrade was needed to bring the country’s transfer pricing norms into line with global standards. January 26, 2011
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Sébastien Gonnet recently transferred to NERA’s Beijing office. January 20, 2011
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Indonesia’s director general of taxation (DGT) has released Regulation No.69/2010, which outlines the procedural requirements taxpayers should follow if they want to obtain an advanced pricing agreement (APA). January 19, 2011
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Rohan Phatarphekar and Manish Bafna, of KPMG, dissect the Mumbai ITAT ruling in the case of Serdia Pharmaceuticals and explain why APIs can constitute a comparable uncontrolled price (CUP) for the import of drugs when the patent has expired. January 19, 2011
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The maximum fine for a Korean taxpayer’s non-compliance in a transfer pricing audit has been increased from W30 million ($27,000) to W100 million. January 19, 2011
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The Indian tax department has released a five-year vision statement, which mentions forming a group of experts, by March this year, to tackle tax leakage and transfer pricing. January 12, 2011
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The proposed 2011 Japan tax reform includes transfer pricing recommendations designed to mirror the changes made to the OECD guidelines, which were updated last year. January 12, 2011
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Representative offices (RO) and other foreign employees, who split their salary payments between China and their home country, may need to comply with China’s transfer pricing regulations for the 2010 audit period. January 12, 2011
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The Thai revenue department intends to look at how it could reform its transfer pricing regulations, in particular, by introducing thin capitalisation rules, to increase revenue collection and close loopholes. January 12, 2011
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China has joined Korea, Japan, the US, Canada, Australia and Italy as one of the first countries to issue a comprehensive report about its Advance Pricing Arrangement (APA) programme. Spencer Chong, Qisheng Yu, and Steven Tseng, of PwC, discuss the contents of the report and its implication for taxpayers. January 05, 2011
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In light of several recent developments in Indian transfer pricing, Rohan Phatarphekar
and Vinita Chakrabarti, of KPMG, provide an overview of key cases and legislation.
January 05, 2011
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Changes to New Zealand’s thin capitalisation rules will come into effect on April 1 2011 as part of the Taxation (GST and Remedial Matters) Act. The act will limit foreign multinationals’ scope to reduce their New Zealand tax liability. January 05, 2011
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India’s Finance Ministry is reconsidering the introduction of safe harbour rules because of the difficulties in implementing them. December 22, 2010
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The Delhi Income Tax Appellate Tribunal upheld, in the case of Abhishek Auto Industries, the company’s arm’s-length justification of the payment of a royalty fee for technical know-how and assistance to a manufacturing entity. December 08, 2010
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The Vietnamese government has released a list of jurisdictions that it considers to be tax havens. The list includes the British Virgin Islands (BVI), as well as Bosnia-Herzegovina, UAE, Lithuania, Albania and a number of other countries. December 08, 2010
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A two-year transfer pricing dispute between the Fijian tax authority and the US subsidiary of Fiji Water has escalated in recent weeks with the company cancelling operations after the government raised tax dramatically. December 07, 2010
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In the Coca Cola India case the Supreme Court said that, because the writ position could not establish the facts of the case, the taxpayer must adopt proceedings before the assessing officer or transfer pricing officer. Hasnain Shroff and Rajan Iyer, of KPMG in Mumbai, analyse the case. December 01, 2010
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The National Tax Agency (NTA) of Japan has released statistics for tax audits, year ending June 30 2010 (FY 2009). December 01, 2010
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China completed its second bilateral advance pricing agreement (BAPA) in October. However, some transfer pricing professionals believe the process is not working properly. November 30, 2010
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The Bangalore Income Tax Appellate Tribunal (ITAT) has ruled in favour of the Commissioner of Income Tax in the case of Gemplus India Pvt. November 24, 2010
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The Tax Directorate General in Indonesia has issued a new regulation on the Joint Agreement Procedure Implementation System to avoid double taxation. November 17, 2010
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The introduction of advance pricing agreements in India has been heralded as the “biggest hope” for transfer pricing in the country, said a panel of top Indian tax professionals. November 12, 2010
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Douglas Fone, Global Partner of Transfer Pricing Associates, explores the implications of new transfer pricing guidelines in Indonesia November 10, 2010
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The Australian Tax Office (ATO) has published the final version of a controversial Taxation Ruling (TR 2010/7) about the interaction between the country’s transfer pricing and thin capitalisation rules. November 03, 2010
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Philippine government sources indicated this week that the Bureau of Customs (BOC) is profiling vehicle imports from a number of other companies which have been allegedly undervalued. November 03, 2010
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Rohan Phatarphekar and Vinita Chakrabarti of KPMG discuss the case which led the Supreme Court to suggest that the transfer pricing rules should also apply to domestic transactions November 03, 2010
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The Delhi bench of the Income-tax Appellate Tribunal in the case of Sona Okegawa Precision Forging Ltd (2010-TII-41-ITAT-DEL-TP), has examined the issue of duplicative services and whether royalty can be paid to the associated enterprise (AE) for sales made to the AE itself. October 27, 2010
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Indonesia’s new transfer pricing rules only confirm what taxpayers believed to be the case already, advisers say. October 27, 2010
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Taxpayers that have not kept up with transfer pricing requirements in Vietnam have until October 20 to regulate their affairs if they do not want to pay a penalty. October 13, 2010
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Spencer Chong and Phillip Mak of PricewaterhouseCoopers emphasise that the tax authorities intend to enforce the rules against all companies that fall within them, not just large multinationals October 06, 2010
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Indian taxpayers have expressed concern about the impending changes to the country’s transfer pricing system, despite the adjustments not being implemented until April 2012. September 29, 2010
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Indian taxpayers have expressed concern about the impending changes to the country’s transfer pricing system, despite the adjustments not being implemented until April 2012. September 29, 2010
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The Chinese tax authorities have formally signed the first automotive-related Mutual Agreement Procedures (MAP) completed in China, which is also the first successful MAP case in Guangdong Province. September 08, 2010
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Australia boasts impressive advance pricing agreement (APA) statistics. To ensure they stay ahead, the Australian Tax Office (ATO) is planning a significant overhaul of the system, a government spokesperson explains. September 06, 2010
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The Australian Taxation Office (ATO) has lodged an appeal to the Full Federal Court of Australia against the recent transfer pricing decision in the SNF case. September 01, 2010
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On August 30 2010, the Indian government tabled a Direct Tax Code Bill 2010 in the parliament. The new code aims to replace the Income Tax Act 1961 and the Wealth Tax Act 1957. If enacted, it will be effective from April 1 2012. September 01, 2010
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After several years of competent authority discussion, a home appliances manufacturer has agreed terms on an advance pricing agreement (APA) with the Chinese tax authorities. August 31, 2010
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The international firm has brought in a solicitor and chartered accountant. August 27, 2010
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The Japanese tax authorities have ordered Hewlett-Packard Japan to pay ¥23 billion ($270 million) in unpaid taxes. August 13, 2010
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A senior transfer pricing official from the Australian Taxation Office is leaving to rejoin Deloitte after 10 years with the tax authorities.
August 04, 2010
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The OECD has approved updates to the Transfer Pricing Guidelines in its first major revision since they were released in 1995. July 28, 2010
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A new circular telling local tax bureaux to carry out a nationwide evaluation of taxpayers’ 2008 and 2009 contemporaneous transfer pricing documentation (CTPD) was released on July 12 by the Chinese tax authorities. July 28, 2010
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Hasnain Shroff and Vinita Chakrabarti report on the Mumbai Tribunal’s ruling in the case of M/s Cheminova India Limited where a higher price paid to associated enterprises was accepted as the arm’s-length price, due to adequate commercial considerations. July 26, 2010
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A service provider has become one of the first companies to take a transfer pricing dispute to the Supreme Administrative Court. July 21, 2010
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Hasnain Shroff, Vinita Chakrabarti and Akash Arora discuss the Nimbus Communications Ltd Vs ACIT, Mumbai (ITA No.2361 (Mum.) of 2007) case and its implications for transfer pricing. July 20, 2010
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Steven Tseng, China partner in charge and Asia Pacific leader for KPMG’s global transfer pricing services is moving to PricewaterhouseCoopers in China, at the same time as many new appointments are made in the US. July 16, 2010
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Australia’s assistant treasurer has released for public comment a discussion paper that represents a further step towards reforming the country’s controlled foreign company (CFC) rules. July 16, 2010
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The Australian government hopes to use international information exchange as part of an increased scrutiny of transfer pricing arrangements. July 13, 2010
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The company reported making a loss of A$107.9 million ($94 million) after being hit with a tax adjustment reportedly relating to intercompany transactions. July 12, 2010
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The Delhi High Court has issued a landmark ruling providing guiding principles on the applicability of the arm’s-length standard to the realm of marketing intangibles. July 12, 2010
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The Chinese tax authorities have identified transfer pricing and anti-avoidance as their main priorities for 2010 and have begun to target to specific industries. July 06, 2010
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The Indonesian directorate general for tax (DGT) has reinvigorated the campaign to crack down on transfer pricing abuse by meeting with advisers from different firms and asking for input before new guidelines are released. July 05, 2010
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An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
June 30, 2010
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The Federal Board of Revenue (FBR) in Pakistan believes pharmaceutical companies have used transfer pricing to evade Rp500 million ($5.8 million) in taxes. June 30, 2010
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The Australian parliament has finally passed reforms to the country’s thin capitalisation rules. June 28, 2010
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The conclusion of a bilateral advance pricing agreement (APA) between the US and the Netherlands will allow FEI, a scientific instruments company, to release large valuation allowance and tax reserves from its accounts for the second quarter of 2010. June 28, 2010
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Chinese taxpayers are being urged to revisit their transfer pricing policies after the tax authorities announced that it is increasing its scrutiny of the country’s automotive industry. June 23, 2010
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The Indian government has released a revised discussion paper on the controversial Direct Tax Code (DTC) containing several provisions that will affect transfer pricing. June 23, 2010
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China and India have leapt up the table to join Japan at the top of the latest TPWeek poll to find the most aggressive transfer pricing officials in the world. June 16, 2010
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Samir Gandhi, Manisha Gupta and Radhi Raman of Deloitte in India discuss the overzealous use of penalty provisions in the country. June 16, 2010
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As part of a firm-wide restructuring, Vaish Associates has promoted two transfer pricing associates to salaried partner level. June 11, 2010
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An Indian court has outlined the three criteria that taxpayers must satisfy to constitute a fixed place permanent establishment. June 09, 2010
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The Australian Tax Office (ATO) has today released a draft taxation ruling on the application of transfer pricing provisions in business restructurings. June 02, 2010
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The tax authorities of Jiangsu, the third largest province in China by GDP and the fifth largest by population, arranged a tax summit to discuss transfer pricing with taxpayers on May 25. May 28, 2010
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Waman Kale and Vinita Chakrabarti report on a judgment by the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) relating to the information technology, business process outsourcing sector. May 27, 2010
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The Chinese State Administration of Taxation (SAT) and the Hong Kong Inland Revenue Department (IRD) held a joint seminar earlier this month in the first public exchange between the two authorities about transfer pricing. May 26, 2010
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K R Girish and Rohan Phatarphekar of KPMG discuss the reported agreement reached by the Indian and US competent authorities. May 26, 2010
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Australian taxpayers are being warned not to give too much information to the country’s tax authorities after a questionnaire was distributed targeting multinational company transfer pricing policies. May 26, 2010
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The release of the first guidance on the use of the Thai advance pricing agreement (APA) system has been met with approval by advisers. May 26, 2010
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Transfer pricing panellists at the Asia Tax Executives’ Forum in Singapore last week stressed the importance of documentation to any taxpayer’s policy in this area May 19, 2010
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Vietnamese taxpayers have just over two weeks to prepare for new transfer pricing guidelines after the Ministry of Finance recently unveiled a list of substantial changes to existing laws. May 19, 2010
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Asia’s senior tax officials are gathering this week in Seoul to discuss ways to tackle transfer pricing abuses in the region. May 17, 2010
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The Indian and US competent authorities have reached an agreement over transfer pricing disputes relating to the mark-up for the software services provided by Indian enterprises to related parties. May 14, 2010
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Rohan Phatarphekar and Hasnain Shroff in India continue TPWeek’s discussion about the DRP process and expand on the practical implementation aspects. May 13, 2010
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Rahul Mitra and Navneet Kothari of PricewaterhouseCoopers in India call for transfer pricing experts to be mandatorily involved in Dispute Resolution Panels (DRP) decisions. May 11, 2010
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One of the world’s largest technology companies is challenging the Indian Directorate of Revenue Intelligence’s biggest claim to date. May 11, 2010
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The Australian government has enraged the mining industry with the announcement of a 40% super tax, in the Henry Tax review. The industry is now facing much larger tax burdens which will threaten the transfer prices in place on resources such as coal. May 10, 2010
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Milap Jain, India’s director general of international tax and transfer pricing, speaks exclusively to TPWeek about his priorities are for 2010 and beyond and how he hopes for greater cooperation with taxpayers. May 05, 2010
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A Chinese tax official has revealed plans to broaden the scope of the country’s anti-avoidance agenda and also provided important statistics from 2009. May 04, 2010
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The Philippines Bureau of Internal Revenue has established a special team to investigate the transfer pricing activity of multinationals operating within the country. April 30, 2010
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China has shown that it is taking a close interest in transfer pricing developments outside its borders by commissioning a translation of an influential international report. April 26, 2010
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Hasnain Shroff and Vinita Chakrabarti report on an interesting case, where it was held that in order to determine the arm’s-length price of an international transaction, the arm’s-length margin should be applied only on the international transaction and not on the entire costs or sales of the taxpayer. April 26, 2010
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Three fiscal authorities in Fiji have signed a memorandum of agreement (MOA) to share information to help them investigate businesses which do not properly document outstanding proceeds from exports. April 21, 2010
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Toray Industries, a leading Japanese chemical manufacturer, has revealed it expects to receive a notice of correction based on transfer pricing issues raised by the Tokyo Regional Taxation Bureau. April 21, 2010
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The Australian Taxation Office (ATO) sent out about 140 transfer pricing questionnaires in the first two months of this year as part of its Strategic Compliance Initiative (SCI), but taxpayers have complained the questions are vague and ambiguous. April 21, 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 comment on increasing documentation burdens for taxpayers in Japan. April 16, 2010
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Jacqueline Shek and Dawn Quek of Baker & McKenzie Hong Kong and Glenn DeSouza of TP Management Consulting in Shanghai evaluate some of the unusual aspects of departmental interpretation and practice note number 46 and assess its implications for companies operating in Hong Kong. April 14, 2010
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Bill Yohana has joined Deloitte in Australia as a partner in the firm’s global transfer pricing group. April 13, 2010
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India’s director-general of international tax and transfer pricing has said thin capitalisation, advance pricing agreements and safe harbour provisions are his three priorities for the coming year. April 13, 2010
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India’s new dispute resolution panels (DRP) will continually adapt to a changing tax environment and greatly improve taxpayer litigation consistency, say two of the country’s leading advisers. April 13, 2010
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New transfer pricing rules included in the tax reform package announced by the Japanese Ministry of Finance in December finally came into effect on April 1. April 07, 2010
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Sanjay Sanghvi and Daksha Baxi discuss the landmark E*TRADE litigation and its implications for the India-Mauritius tax treaty. April 06, 2010
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The State Administration of Taxation (SAT) in China has issued a circular that further clarifies certain aspects of the country’s tax law. April 06, 2010
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The tax burdens of overseas fee payments from China have unavoidably increased due to the recent issuance of circulars and tax reforms, a leading tax professional has said. March 31, 2010
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The US Advance Pricing Agreement (APA) Program has announced it received 127 applications for agreements last year, only four more than in 2008. And yet, the time taken to process important bilateral APAs has increased by more than four months. March 31, 2010
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Steven Tseng, Chi Cheng, Kari Pahlman and Nathan Richards of KPMG China outline the transfer pricing documentation guidelines in Hong Kong and China. March 29, 2010
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A decision by the Indian Authority for Advance Rulings concerning permanent establishments (PE) has been heavily criticised by tax professionals and is likely to affect foreign multinationals operating in the country. March 18, 2010
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Hasnain Shroff, Sanjeev Gupta and Tarini Nijhara in India look at the unreported judgement in the case of IL Jin Electronics (India) Private Limited. March 15, 2010
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Komatsu, a Japanese construction equipment manufacturer, has announced 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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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