Asia Pacific

• South-East Asia looks to tighten transfer pricing rules

  Countries in South-East Asia are introducing or reforming their transfer pricing rules to increase revenues and attract foreign investment November 19, 2008

• Indian authorities scrutinise cross-border restructuring

  Atul Jain and Manisha Gupta of KPMG examine how the Indian tax authorities will approach modern business restructuring November 18, 2008

• Thai court changes rule on share values

  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

• Incoming government puts off transfer pricing changes in New Zealand

  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

• India should introduce APAs and change data rules

  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

• Industry body demands changes in India

  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

• China’s tax restructure will hit large firms

  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

• Singapore proposes transfer pricing guidance for loans and services

  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

• Thin capitalisation adopted in China

  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

• Korea proposes penalty relief for taxpayers maintaining contemporaneous documentation

  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

• Korean National Tax Service releases APA annual report

  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

• NERA Economic Consulting expands presence in China

  NERA Economic Consulting opens Beijing office  October 14, 2008

• KPMG adds to transfer pricing practice in China

  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

• Bangalore Tribunal overturns official’s action

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

• Proposed amendments to Japanese transfer pricing guidelines

  Chris Newman and Jon Jenni from Ernst & Young Shinnihon Tax, Tokyo describe possible changes to Japan’s transfer pricing legislation  September 29, 2008