Americas

• Global documentation burden increases

  The burden of keeping up with transfer pricing documentation requirements is becoming one of the biggest challenges for multinational corporations, with some taxpayers having to prepare upwards of 500 transfer pricing reports a year  December 17, 2008

• Decision on basket approach creates unfavourable Brazilian precedent

  One of the several controversial aspects of Brazil's transfer pricing legislation is the possibility for taxpayers to take into account the “basket approach” criterion to calculate the parameter price. Henrique de Freitas Munia e Erbolato of Machado Associados explains. December 16, 2008

• More Canadian taxpayers choose APAs

  The Canada Revenue Agency (CRA) recently released its annual report on advanced pricing agreements (APAs) covering the fiscal period ending March 21 2008. December 10, 2008

• Using transfer pricing as a repatriation tool during economic downturns

  During economic downturns, US-based multinationals may find themselves wanting to repatriate cash from foreign subsidiaries. Under such circumstances, transfer pricing may provide a useful mechanism to achieve this in a tax-efficient manner. Mike Murphy, Albert Liguori and Julie Smith of Alvarez & Marsal Taxand explains how December 03, 2008

• How transfer pricing works in Colombia

  Transfer pricing regulations were introduced in Columbia in 2004, Carlos Mario Lafaurie Escorce and Ricardo Suarez of PricewaterhouseCoopers explain the requirements of the laws. December 02, 2008

• Advisers criticise profit margin in resale price less profit method

  Brazilian transfer pricing rules adopt fixed profit margins in methods applicable to import transactions. Fabia Moreira Azevedo of Machado Associados explains why many are critical of the percentage profits margins allowed under the rules November 18, 2008