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The Portuguese tax authority has turned its transfer pricing focus to residual pricing methods, meaning companies should stop using them if they want to save money. February 02, 2012
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Historically, Sweden has been seen as something of a tax haven, at least in terms of the availability of interest deductions. However, David Perrone and Anna Karlgård, of KMPG, explain why this will soon change. January 30, 2012
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The UK team has also undergone a number of internal changes. January 24, 2012
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Whether the euro breaks-up or whether the EU can hold it together, taxpayers should be aware of the implications a break-up would have on their transfer pricing arrangements. January 24, 2012
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The European Tax Awards are expanding this year, with the inclusion of South Africa. January 18, 2012
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The new head of the OECD's tax treaty, transfer pricing and financial transactions division has been named. January 11, 2012
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Russian companies with significant foreign capital and high debt to equity ratios, are at risk of attack by the tax authorities following a recent Supreme Arbitration Court (SAC) ruling. January 10, 2012
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The Netherlands has introduced a deduction for capital expenditure associated with R&D, effective January 1 2012, which has implications for transfer pricing. January 10, 2012
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HMRC in the UK has released for the first time extensive statistics about its transfer pricing enquiries, advance pricing agreements (APAs), and mutual agreement procedure (MAP). December 20, 2011
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By Danny Beeton, Murray Clayson and Michael Blau of Freshfields Bruckhaus Deringer December 16, 2011
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By Danny Beeton, Murray Clayson and Michael Blau of Freshfields Bruckhaus Deringer December 16, 2011
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The UK Treasury today released draft legislation on the creation of a patent box for intellectual property (IP) management. December 06, 2011
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Norway’s Supreme Court has ruled that Dell Products, a Norwegian commissionaire company, does not constitute a sales agency permanent establishment (PE) in Norway. December 05, 2011
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In transfer pricing, the main problem for practitioners is to choose which method they will use to calculate an arm’s-length price. They must also decide which profit level indicator (PLI) they will select to support their argument. November 23, 2011
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Taxpayers in Poland are not taking advantage of the country’s advance pricing agreement (APA) regime because of the length of time it takes to complete an application, statistics reveal. November 21, 2011
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The EU Joint Transfer Pricing Forum (JTPF) will focus on cost sharing agreements (CCA) in service arrangements. Intangible assets, however, will be left out of the discussions. November 15, 2011
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The second refusal of the UK Supreme Court to refer the Thin Cap GLO to the ECJ has been described as “inconsistent” and “wrong” and will end up costing taxpayers a lot of money if they decide to persist with the litigation. November 07, 2011
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Gazprom, one of the world’s biggest energy producers, is rumoured to have applied for an advance pricing agreement (APA) with the Russian tax authorities, after requests to be excluded from the new transfer pricing regulations. November 04, 2011
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Norway does not have a formal advance pricing agreement (APA) programme but some taxpayers are achieving advance agreements with the authorities and the process is getting quicker. A pilot programme is now in place. October 25, 2011
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The adoption of the Tax Code by the Ukrainian Parliament at the end of 2010 has become a milestone event for the Ukrainian business community, including a substantial revision of the transfer pricing regulations. Yuliya Nogovitsyna and Anna Vitko, of KPMG, provide an overview of the new regulations and their impact on taxpayers operating in the Ukraine. October 24, 2011
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One year on, the Norwegian tax authorities annual report shows transfer pricing is still a key focus area. Amrit Paul Singh and Hans-Martin Jørgensen of Deloitte explain why. October 14, 2011
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HM Revenue & Customs has updated the guidance in its international manual for taxpayers, including changes to the transfer pricing provisions. October 12, 2011
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October 05, 2011
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October 04, 2011
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Micro-blogging site Twitter has announced its European headquarters will be based in Ireland, joining a number of other hi-tech companies, to make use of its 12.5% corporate tax rate and beneficial transfer pricing regime. October 04, 2011
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European tax officials gave delegates at the Global Transfer Pricing Forum last week an insight into the issues they look for when assessing taxpayers. September 28, 2011
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The European transfer pricing panel, on day one of International Tax Review’s Global Transfer Pricing forum yesterday, was boosted by revenue officials from the Netherlands, Spain and France. September 21, 2011
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A panel of experts at International Tax Review’s 11th annual Transfer Pricing Forum said there is a lot of positivity around the advance pricing agreement (APA) programme in the UK, and complimented the UK tax authorities for their commitment to the programme. September 21, 2011
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The District Court of the Hague has ruled, in a transfer pricing dispute, that the profits of an Irish reinsurance company are considered taxable income for its Dutch shareholder. Eduard Sporken and Dirk Brouwers of KPMG Meijburg & Co discuss the case and its implications. September 12, 2011
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The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday. September 12, 2011
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Paul Smith and Wendy Nicholls of Grant Thornton UK welcome the new patent box proposals but believe the take-up will be small because of the restriction to patents and the highly complicated calculation of patent box profits. September 12, 2011
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The Baltics region has witnessed increased transfer pricing development in recent years but practitioners say more guidance is needed. September 07, 2011
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Forget player transfers, it’s transfer pricing that could put Manchester City Football Club under the microscope of football’s governing body, UEFA. August 31, 2011
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An international research centre will launch in the Netherlands next month to study and analyse transfer pricing issues to assist multinationals (MNE) and governments to deal more effectively with the increasing complexity of transfer pricing. August 24, 2011
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Advisers in Estonia have said the new transfer pricing guidelines, introduced by the Tax and Customs Board, are not comprehensive enough for taxpayers. August 17, 2011
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Discrepancies between the OECD guidelines and Russia’s new transfer pricing legislation, which the president signed into law last month, could cause problems for international groups.
August 10, 2011
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Weeks after Turkey agreed its first unilateral advanced pricing agreement (APA) on July 15 and more than three years after taxpayers were eligible to apply for them, interest in APAs remains thin on the ground. August 10, 2011
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A torrent of criticism has followed the EU’s release of a transfer pricing report on developing countries. August 03, 2011
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July 29, 2011
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After years of delay, the Russian parliament has finally passed the new transfer pricing rules, though there have been significant amendments. July 20, 2011
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Turkey hopes to move on to negotiating bilateral advance pricing agreements after the signing of its first unilateral APA last week. July 20, 2011
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Deloitte's new partner is based outside London. July 13, 2011
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The Italian tax authorities have released guidelines on accessing the transfer pricing penalty protection regime. The transfer pricing rules themselves remain unaffected, but the guidelines clarify the procedure for application to obtain penalty protection.
July 11, 2011
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Rudolf Sinx has become a global partner of the TPA Global Group. July 08, 2011
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Taxpayers in France should be aware that they still need to justify their choice of comparables, even if the authorities have limited scope to make adjustments in this area, explain Jean-Luc Trucchi and Edouard Berthelot of Taj
July 06, 2011
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Stefaan De Baets, a senior OECD representative, said the up-coming Working Party 6 meeting in November, to discuss the transfer pricing aspects of intangibles, would focus on valuation methods. June 27, 2011
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Denmark has signed a third bilateral advance pricing agreement (BAPA) with China. It is the only European country to have signed even one. June 24, 2011
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By Barbara Dooley and Gavan Ryle of PwC, Dublin. June 23, 2011
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Taxpayers are finding it more difficult to comply with the growing amount of transfer pricing documentation requirements. June 22, 2011
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In the run-up to the general election in Denmark, which must be held by November 12, multinational entities (MNEs) have been the focus of political debate over the amount of taxation they pay. Transfer pricing in particular has proved controversial.
June 17, 2011
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By Mike Ahern, Piotr Wiewiorka, and Przemyslaw Orwat, of PwC Poland June 14, 2011
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A Czech Supreme Administrative Court ruling has set groundbreaking rules for the burden of proof in transfer pricing cases. Libor Frýzek and René Kulínský, of Ernst & Young, discuss. June 10, 2011
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A French company has lost its appeal at the Nantes Administrative Court over the burden of proof and the assignment of affiliated company liabilities in transfer pricing. June 08, 2011
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A new draft law in Latvia, proposing changes to the transfer pricing system, was announced by the State Secretaries last month. June 08, 2011
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By Henrik Hansen, Evgenia Veter and Alexey Sobchuk of Ernst & Young, Russia June 03, 2011
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By Marianna Dozsa and Bettina Dorfer PwC, Austria June 01, 2011
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The resignations of Mary Bennett and Caroline Silberztein from the OECD last week provoked wide-spread speculation, above all because their jobs were advertised simultaneously, suggesting all is not well in the OECD’s corridors of power. June 01, 2011
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The OECD ministerial meeting in Paris had a strong focus on both tax and the developing world and, as such, transfer pricing issues were also raised. June 01, 2011
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By Isabel Verlinden, Leticia Ortega and Jurgen Meersman of PwC, Belgium May 27, 2011
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The leading female practitioners in Europe for tax, transfer pricing, tax dispute resolution and trusts and estates advice will be honoured at the first European Women in Business Law awards in London on June 29.
May 26, 2011
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Draft regulations on the French thin capitalisation rules have been released by the French tax authority (FTA). May 25, 2011
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By Javier González Carcedo and Leticia Ortega of PwC, Spain May 24, 2011
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The jobs of both Caroline Silberztein, the OECD's head of the transfer pricing unit in the tax treaty, transfer pricing and financial transactions division, and Mary Bennett, the head of the division itself, were advertised by the OECD in May.
May 24, 2011
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The EU’s Joint Transfer Pricing Forum (JTPF) has been accused of bias because of its composition. May 18, 2011
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The OECD has sent out a report that welcomes the Russian’s progress towards the revision of its transfer pricing law. May 18, 2011
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By Alexander Voegele and Jean-Benoit Voegele of NERA Economic Consulting May 17, 2011
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The OECD’s proposed Global Forum for transfer pricing, which will institutionalise the involvement of developing countries, may detract from the UN’s tax committee and the work it is doing for developing countries, a spokesman for a non-governmental organisation has told TPWeek. May 17, 2011
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Panelists at the April 2011 International Bar Association, International Fiscal Association 11th Annual Tax Planning Strategies, US and Europe conference in Paris discussed a key aspect of the current OECD project on the transfer pricing of intangibles, namely the specification and resolution of the intangible issues that can arise in a business restructuring. May 11, 2011
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The Dutch government has rejected the recent EU proposals for a Common Consolidated Corporate Tax Base (CCCTB), citing a number of key objections to the proposals including the issue of allocation keys. May 11, 2011
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The Irish Revenue Commissioners has confirmed that a small number of transfer pricing audits will take place later this year. May 04, 2011
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The updated members list for the EU Joint Transfer Pricing Forum (JTPF) has been announced. Their mandate is effective from April 1 2011. April 26, 2011
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The tax authorities in Luxembourg issued Circular LIR 164/2 bis, on April 8, which serves to clarify transfer pricing rules for resident taxpayers. April 20, 2011
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The deadline for the OECD's project on the transfer pricing aspects of intangibles has been described as ambitious by some and unrealistic by others.
April 14, 2011
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Caroline Silberztein, head of the OECD’s transfer pricing unit, has said the organisation's guidance on intangibles is insufficient, as it stands, and considered old and out-of-date.
April 14, 2011
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The top official at HM Revenue & Customs confirmed that the UK is to lead a survey into the practicality of global transfer pricing guidelines.
April 14, 2011
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Media company, Bloomberg, will not appeal a Russian court decision that said its Russian operations constituted a permanent establishment (PE). April 13, 2011
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The number of field audits may be increasing globally, but the auditors’ approach in each jurisdiction is not the same. April 13, 2011
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The Department of Finance in Dublin said it is unlikely to adopt the recommendations of a group of six Irish charities to adapt the transfer pricing regime. April 13, 2011
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By Peter Flipsen and Anouc van den Berg, of Simmons & Simmons Amsterdam. April 13, 2011
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A Norwegian Court of Appeal ruled on March 2 that Dell AS, a Norwegian commissionaire company, constituted a sales agency permanent establishment (PE) in Norway because of its undisclosed Irish principal. April 11, 2011
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Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC). April 06, 2011
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Six Irish charity organisations, collectively called the Debt and Development Coalition Ireland (DDCI), have called on their government to reform the transfer pricing regime. April 06, 2011
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By Hannu-Tapani Leppänen and Reima Linnanvirta of Alder & Sound April 05, 2011
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By Sylvain Chevrier of Taj, Société d’Avocats, member of Deloitte April 05, 2011
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By Hans-Martin Jørgensen and Nick Pearson-Woodd, Deloitte, Oslo. April 01, 2011
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Caroline Silberztein, head of the OECD’s transfer pricing unit, hinted that credit ratings and guarantee fees may be the next project for the OECD, after the transfer pricing aspects of intangibles.
March 30, 2011
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The Czech Republic is to set up a new specialised tax authority, for enterprises whose annual turnover is more than CZK2 billion ($115 million).
March 30, 2011
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Advisers have said the reason behind the delay for transfer pricing rules in Russia is because of unresolved issues about substance, including the mechanism for correlative adjustments and the provisions dealing with the period in which the tax authorities can conduct transfer pricing audits. March 23, 2011
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The European Commission today unveiled its proposal for a common consolidated corporate tax base (CCCTB) system for calculating the tax base of businesses operating in the EU. March 16, 2011
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A source from the European Commission has spoken exclusively to TPWeek about the common consolidated corporate tax base (CCCTB) proposal, before it was announced today. March 15, 2011
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Last year was a milestone for transfer pricing in Romania and set a trend of aggressive tax audits and transfer pricing adjustments.
Adrian Luca and Andreea Jora of Transfer Pricing Services in Bucharest provide an update on the latest legislative and practical developments.
March 15, 2011
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The OECD is inviting comments on its new project on the administrative aspects of transfer pricing.
March 10, 2011
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A new tax Bill which was heard and voted for in principle in the Greek parliament last week, and which will be voted on again next week, means investment firms are now exempt from the application of thin capitalisation rules. March 09, 2011
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French companies are showing an increased interest in tax planning because of global competitiveness and the economic downturn, advisers have told TPWeek. This is having an effect on profit allocation. However, public opinion is making taxpayers think twice about using structures that are seen to avoid too much tax. March 04, 2011
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Socialist Party members of the French parliament, the largest party of the French centre left, have voiced their concern about the necessity of the R&D tax credit and its future benefit. March 02, 2011
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Luxembourg tax legislation makes reference to the arm’s-length principle in the different articles of the Luxembourg Income Tax Law (LITL). March 02, 2011
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The Court of Appeal has ruled that UK thin capitalisation legislation is compatible with EU law, overturning a previous decision, on appeal from HM Revenue & Customs (HMRC). February 28, 2011
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Foreign banks with permanent establishments (PE) in the UK may have difficulty in providing an accurate calculation for the bank levy, which was introduced in January this year. February 25, 2011
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The common consolidated corporate tax base (CCCTB) is a recurring debate in the Eurozone. A draft proposal is expected by the end of March. If it is implemented, companies will have to rethink how they organise their tax and transfer pricing affairs in the EU. February 23, 2011
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After more than a decade since guidance was last issued, HM Revenue & Customs (HMRC) has issued a full statement of practice which will give taxpayers greater clarity on its approach to the underused mutual agreement procedure (MAP). February 23, 2011
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A UK economist has told TPWeek that UK taxpayers do not want lawyers and accountants to approach them with tax planning arrangements because the risk of being exposed by the media is too great. February 22, 2011
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The Italian Austerity Package, issued in May last year, gave companies the chance to provide transfer pricing documentation to avoid audits or face penalties ranging from 100% to 200%. February 16, 2011
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The Dutch government has issued a decree on the attribution of profits to permanent establishments (PE). February 16, 2011
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The operating methods of multinationals across the world are under greater scrutiny from tax authorities. In particular, transfer pricing and permanent establishment (PE) are more closely monitored. February 16, 2011
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Guidance from the Luxembourg tax authorities on transactions by group finance companies helps to clarify what is expected of taxpayers.
February 04, 2011
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Transfer pricing will feature strongly in the European Tax Awards 2011 which will be presented in London in May. February 02, 2011
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The European Commission announced yesterday it will extend the mandate of the EU Joint Transfer Pricing Forum (JTPF) until March 2015. January 26, 2011
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The French tax authorities (FTA) have been conducting raids on the offices of French companies in an attempt to prove the existence of permanent establishments (PE). January 24, 2011
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Enrico De Angelis and Caterina Colling have both joined joined the TPA team in Italy. January 20, 2011
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In a decision that represents binding case law, the Supreme Administrative Court in Finland has delivered a ruling on the determination of arm’s-length rate of interest in intra-group financing structures. January 19, 2011
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The Supreme Tax Court in Germany has clarified that not only did the country’s old thin capitalisation rules not comply with the freedom of establishment provision of the European Community (EC) treaty, but they also infringed the non-discrimination clause of treaties relating to companies resident in non-EC countries. January 19, 2011
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Serbia plans to crack down on tax evasion by enforcing transfer pricing regulations more strictly as it tries to revive the economy after the international downturn. January 19, 2011
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A new transfer pricing consultancy opened its doors in Amsterdam on November 1. January 12, 2011
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A new transfer pricing consultancy opened its doors in Amsterdam on November 1. January 10, 2011
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Transfer Pricing Associates, the independent provider of transfer pricing and valuation services around the world, has added to its list of strategic allies. January 10, 2011
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Taxpayers in Russia will have to wait much longer than they thought for new transfer pricing rules after the State Duma failed to adopt the law in time for their enactment, as expected, on January 1. January 05, 2011
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The Belgian tax authorities have finally published a circular clarifying the scope of a year-old law, requiring companies to report all payments made to tax havens that are more than a total of €100,000 ($131,000) in the tax year. December 22, 2010
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The French Parliament, on December 15, adopted an amendment to the thin capitalisation rules, bringing all financing between related parties, within the scope of the limitations of the rules. December 22, 2010
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A chain of pharmacies has cut its UK tax bill by £80 million ($125 million) since it left the London Stock Exchange and moved its tax residency to Switzerland, despite a rise in sales and trading profits. December 20, 2010
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Multinational companies in Italy run the risk of being audited if they do not comply with new guidance on transfer pricing documentation. December 20, 2010
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Draft clauses for Finance Bill 2011 in the UK refer to the updated OECD guidelines of July 2010 and make clear that, for accounting periods beginning on or after April 1 2011, this version is the one for business to refer to. December 10, 2010
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A member of the EU Joint Transfer Pricing Forum has said the latest changes to the OECD transfer pricing guidelines fall into three categories. December 01, 2010
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Transfer pricing could be the biggest obstacle to equalising the corporate tax rate in the north and south of Ireland, a UK parliamentary committee has been told. November 29, 2010
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The Kazakhstan tax authorities have made a $1.2 billion claim, including transfer pricing charges against the Karachaganak Petroleum Operating Group (KPO) for unpaid taxes between 2005 and 2008, a Reuters report revealed. November 10, 2010
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France’s new documentation requirements are helping clients to iron out the creases in their transfer pricing policies. October 27, 2010
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In an exclusive interview, Algirdas Šemeta, European Commissioner for Taxation and Customs Union, Audit and Anti-Fraud, said that a common consolidated corporate tax base (CCCTB) will end transfer pricing disputes between member states and taxpayers within its zone. October 20, 2010
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Regulations enabling binding, unilateral advanced pricing agreements (APAs) in Austria will be effective from January 1 next year. September 29, 2010
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Deloitte in the UK has appointed Heather Devine as a director within its business model optimisation team, part of the transfer pricing group. September 29, 2010
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HM Revenue and Customs in the UK has released a draft Statement of Practice on advance pricing arrangements (APAs) to update its 1999 statement.
September 29, 2010
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The draft statement of practice contains some welcome features, such as an openness to arbitration and more guidance on when invoking the mutual agreement procedure is appropriate, believe Murray Clayson and Danny Beeton of Freshfields Bruckhaus Deringer September 22, 2010
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The debate on the future of the arm’s-length standard (ALS), at International Tax Review's Global Transfer Pricing Forum in Amsterdam today, concluded that, while interesting arguments exist for an alternative method, the ALS is the only viable option because of its close connection to what happens in the market.
September 15, 2010
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Taxpayers need to pay special attention to the structures and value-added approaches to their sourcing operations, a group of leading tax professionals said today.
September 15, 2010
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In a TPWeek roundtable, tax disputes specialists discuss alternative dispute resolution (ADR) and whether there is a place for a formal mediation process in the UK. September 10, 2010
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The Intercompany financial transactions talk at International Tax Review’s Transfer Pricing Forum in Amsterdam this month will be moderated by Antonio Russo of Baker & McKenzie in the Netherlands. September 08, 2010
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Tax authorities from across the world should pay close attention to the way the Dutch authorities interact with taxpayers, a leading tax adviser has said. September 08, 2010
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The panel titled Technology-based IP and Transfer Pricing at International Tax Review’s Global Transfer Pricing Forum, will focus on the migration of trade IP, dealing in practice with distributed IP development, franchising technology intangibles, variable royalty structures, recurring tax audit themes and US and OECD developments. September 06, 2010
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Advisers and business representatives will come together at International Tax Review’s Global Transfer Pricing Forum to share experiences in transfer pricing over the last year and deliberate how the new OECD guidelines will affect them. September 06, 2010
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The Danish tax authorities have caused a stir among corporate taxpayers by releasing an action plan which will probably lead to a crack down on transfer pricing. September 01, 2010
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The first topic up for discussion at International Tax Review's Global Transfer Pricing Forum in Amsterdam next month is the future of the arm’s-length standard. September 01, 2010
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The dispute resolution panel at International Tax Review's Global Transfer Pricing Forum will focus on planning transfer pricing policies to avoid disputes, achieving settlements and using advanced pricing agreements (APAs).
September 01, 2010
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Taxpayers need to pay special attention to the structures and value-added approaches to their sourcing operations, a group of leading tax professionals has said. September 01, 2010
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Marketing intangibles is something that taxpayers should not take lightly as no single approach applies to all business, says one leading transfer pricing adviser. September 01, 2010
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A valuation specialist from the World Customs Organisation (WCO) will give a keynote address at International Tax Review’s Global Transfer Pricing Forum in Amsterdam on September 15 and 16. August 25, 2010
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The UK Pensions Regulator’s decision to issue its second ever Financial Support Direction against 25 companies in the Nortel Group in Canada, the US, Europe and Africa is because, in part, of an investigation into the telecommunications group’s transfer pricing arrangements. August 04, 2010
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Yvonne Cypher joined the firm in 1997 and specialises in transfer pricing with a particular focus on business restructuring. July 28, 2010
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Her Majesty’s Revenue and Customs (HMRC) is to release figures relating to the negotiation of advance pricing agreements (APAs) and “other aspects of transfer pricing” imminently. July 27, 2010
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As part of the overhaul of Greece’s tax system, transfer pricing rules have been strengthened, including raising the penalty for not submitting documentation to 20% of the amount of the transaction. July 21, 2010
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Companies adopt a wait and see attitude to Russia’s new transfer pricing rules. July 14, 2010
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The acquisition by LECG, a global business advisory and professional services firm, of Bourne Business Consulting, a London firm, closed on July 2. July 13, 2010
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David Borkovec has been made a partner in the PricewaterhouseCoopers tax and legal services department in Prague. July 13, 2010
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Helga Marie Andresen and Merethe Bryn of Deloitte in Norway discuss the court’s ruling in the landmark case of ConocoPhillips, which shifted the tax authority’s approach to evaluating whether Norwegian companies receive their part of the profit compared to the group as a whole. July 12, 2010
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The OECD has announced it may begin a project to investigate the issues of transfer pricing involving intangible property, much to the approval of specialists in the field. July 07, 2010
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Fashion retailer, H&M, has been criticised for its operations in Bangladesh and tax payments amounting to transfer mis-pricing. July 07, 2010
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The first six months of 2010 in the international transfer pricing market has seen a significant rise in recruitment activity across all industry sectors. July 07, 2010
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Taxpayers are looking into how a common corporate tax base might affect transfer pricing after a new report into how to complete the EU single market lent support to the plans of Algirdas Šemeta, European commissioner for tax, to introduce a proposal on the measure. July 06, 2010
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Gianmarco Monsellato and Sylvain Chevrier of Taj, a member of Deloitte Touche Tohmatsu, answer commonly asked questions about the implementation of the new French documentation rules. July 06, 2010
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International Tax Review’s 10th annual Global Transfer Pricing Forum will be an opportunity for transfer pricing professionals from business, government and private practice to focus on the key issues in related-party transactions. July 06, 2010
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Transfer pricing documentation requirements introduced under Law decree number 78 will provide clearer guidance for Italian taxpayers. June 23, 2010
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The UK coalition government’s first budget contained some provisions that will interest transfer pricing practitioners and cause alarm among the financial industry in particular. It also raised the prospect of a general anti-avoidance rule in the UK. June 23, 2010
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Eduard Sporken and Neil Schaatsbergen provide background information on APAs/ATRs in the Netherlands and comment on the related statistics recently published by the Dutch tax authorities. June 22, 2010
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Companies operating in Poland are being forced to remain vigilant to avoid falling foul of the country’s strict transfer pricing rules which require documentation submitted in Polish within seven days of request. June 16, 2010
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In Tax Briefing Issue 07 of 2010, released on June 10, the Irish tax authorities have issued guidance on the documentation that is required from taxpayers to comply with the new transfer pricing rules. June 15, 2010
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Akin Gump Strauss Hauer & Feld is opening a new office in Geneva, Switzerland. New partner Jonathan Ivinson has significant transfer pricing experience. June 11, 2010
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Tax directors from multinational companies expressed alarm over shifts in transfer pricing trends during a panel at the joint American Bar Association and International Fiscal Association event in Copenhagen. June 09, 2010
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A mutual agreement between the Netherlands and the US which amends the procedure of obtaining an exemption from dividend withholding tax under the Netherlands-US tax treaty makes sense as it affords the US government responsibility for deciding if US entities qualify for relief under the treaty. June 09, 2010
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On May 31 the Italian government issued law decree number 78 (to be converted into law within a 60 day maximum term) that introduces transfer pricing documentation requirements in the Italian statutes. June 02, 2010
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A mutual agreement has been settled between the competent authorities of the Netherlands and the US which amends the procedure by which US pension funds obtain an exemption from dividend withholding tax under the Netherlands-US tax treaty. June 02, 2010
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The Norwegian tax authorities recently won its overhead costs case against Enterprise Oil Norway (EO) in the Norwegian courts, because EO could not provide sufficient documentation to show that it had received the services that it had paid for. May 28, 2010
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PricewaterhouseCoopers retained its title as European Transfer Pricing Firm of the Year at International Tax Review’s European Tax Awards in London last night. May 19, 2010
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Stefaan De Baets, First Attaché of Finances at the Belgian Finance Ministry, along with representatives from the country’s competent authority and the transfer pricing audit teams reveal how ECJ rulings may alter transfer pricing in the country. May 12, 2010
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A draft bulletin officiel des impôts released by the French tax authorities, intended to help taxpayers and practitioners understand the changes to transfer pricing rules in the country has instead deepened the confusion. May 12, 2010
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Alex Cobham, chief policy adviser at Christian Aid, responds to comments in a recent report criticising the charity’s research into transfer mis-pricing. May 05, 2010
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Discussions about the best use of transfer pricing documentation sparked debate among panellists and audience members over how much information companies should provide and to whom they should give it. May 05, 2010
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The International Tax Ruling office of the Italian Revenue Agency (IRA) has issued its first advance pricing agreement (APA) bulletin since the country’s APA programme became effective in 2005. May 05, 2010
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Alberto Pluviano is set to join Charles River Associates in Paris on May 17. May 05, 2010
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Gordon Hands of CUFTanalytics explains how taxpayers can assess the arm’s-length dividend rate for intercompany preferred share issuances. April 20, 2010
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The Danish tax authorities have collected DKK 15 billion ($2.8 billion) from transfer pricing audits of 32 multinational companies. April 15, 2010
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A controversial system of global profit reporting is gaining support as the European Commission is asked to examine how country-by-country reporting could become the norm in Europe. April 14, 2010
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A report published by Jersey Finance concludes the data contained in two studies conducted by Christian Aid is flawed. April 14, 2010
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Gordon Hands of CUFTanalytics examines two example cases, an interest rate swap and a factoring transaction, where expected loss (EL) is used to price the credit risk portion of the intercompany financial transaction. April 14, 2010
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In March 2010 HM Revenue & Customs (HMRC) released an update of the guidance in its International Manual on the UK’s thin capitalisation rules. This guidance is prepared primarily to assist inspectors of taxes in applying the thin cap legislation, but also offers useful insights into HMRC policy for taxpayers and advisers. April 07, 2010
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Polish taxpayers have been sent a strong warning after the country’s tax authorities confirmed that they will focus their 2010 audit work on transfer pricing and its associated issues. April 07, 2010
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Ian Dykes has taken over from Steve Hasson as UK transfer pricing leader at PricewaterhouseCoopers. April 06, 2010
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It is hoped the new protocol will boost multilateral cooperation and reduce cross border tax evasion. April 06, 2010
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A survey by accounting firm KPMG found 82% of respondents said they faced the same level of transfer pricing controversy as last year. In Spain there was a significant increase, however. April 06, 2010
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Gordon Hands of CUFTanalytics discusses the merits of external credit ratings and forward-looking probability of default as credit risk measures when selecting comparable uncontrolled financial transactions (CUFTs) April 06, 2010
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Nine firms will compete for the top award of European Tax Firm of the Year at International Tax Review's fifth annual European Tax Awards in London in May. March 31, 2010
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Statistics released by the US Bureau of Economics show US companies invested $21.9 billion in Ireland in 2009, only a slight drop from the $22 billion invested in 2008 despite the discussions over introducing transfer pricing rules to the country. March 31, 2010
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In his 2010 budget speech, Alistair Darling, the chancellor of the exchequer, said that £2 billion ($3 billion) has been raised by the UK bank payroll tax. Advisers believe that this may have implications for financial institutions’ transfer pricing arrangements. March 31, 2010
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The first-tier tax tribunal in the UK has cast doubt over the UK tax treatment of US limited liability companies (LLCs) in the decision Mr Swift v The Commissioners for HMRC ([2010] UKFTT 88 (TC)). March 31, 2010
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Bulgaria’s National Revenue Agency (NRA) has published guidelines on transfer pricing documentation, finally clearing up what is expected of taxpayers. March 24, 2010
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TPWeek is proud to announce the 10th annual Global Transfer Pricing Forum will take place in Amsterdam on September 15th and 16th 2010. March 24, 2010
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The nominees for the national tax and transfer pricing awards in International Tax Review's European Tax Awards 2010 are announced today. March 24, 2010
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Russian multinational companies are already making changes to their transfer pricing policies nine months ahead of the country’s new law, a leading tax professional has said. March 24, 2010
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Lucijan Klemencic of Ernst & Young explains the transfer pricing documentation requirements in Slovenia. March 24, 2010
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Multinationals are paying significantly more tax to resolve transfer pricing disputes. With litigation a costly and time consuming option for both the taxpayer and the tax authority, thoughts are turning to alternative dispute mechanisms. March 24, 2010
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The Hungarian tax authorities are focusing their attention on the detailed transfer pricing arrangements of companies, going beyond investigations of documentation compliance that taxpayers are used to. March 17, 2010
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Transfer pricing executives and their advisers are dismissive of the news that Algirdas Semeta, the new EU tax commissioner, wants to see a common consolidated tax base (CCCTB) in place as soon as possible. March 12, 2010
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The OECD group responsible for consultations on transfer pricing will soon begin to consider the issues concerning the taxation of intangibles, including a comprehensive definition and appropriate valuation methods. March 12, 2010
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Taxpayers should view litigation as the last resort for resolving transfer pricing disputes, senior tax executives and practitioners told a conference in London. March 12, 2010
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The head of transfer pricing at the leading technology multinational company says that streamlining documentation processes reduced costs at the firm by as much as 50%. However, its original masterfile strategy did not meet all the company’s requirements. March 10, 2010
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Marko Saag of Glimstedt Straus & Partners Law Firm explains the transfer pricing documentation obligations in Estonia. March 09, 2010
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Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime. March 08, 2010
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Dirk Van Stappen of the KPMG in Belgium, provides a definitive guide to transfer pricing documentation policy. March 01, 2010
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Mirko Rapa and Berta Pisani Bencini of PricewaterhouseCoopers in Malta describe the country's documentation requirements March 01, 2010
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Germany has produced draft legislation that seeks to soften the transfer of function rules. The draft legislation would reform the exit charge that a company pays when it transfers its assets. February 26, 2010
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Denes Szabo, tax partner and Hedvig Solyomvari, senior manager at Ernst &Young Budapest outline the transfer pricing documentation framework in Hungary. February 25, 2010
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Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine February 25, 2010
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TPWeek is refreshing the content found in the documentation guide section of the website, be sure to take a look. February 25, 2010
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An eagerly awaited UK transfer pricing case will not now go to court. February 24, 2010
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A case that has just been decided in the Czech Supreme Administrative Court (SAC) provides an important discussion on transfer pricing methodology in disputes with the tax authorities in the context of the Czech tax law. February 23, 2010
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Professionals harbour fears over inconsistent implementation across Europe and some go so far as to question whether the system change was necessary. February 17, 2010
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Specialist insurance company Beazley made a pre-tax profit of £100.7 million ($156 million) in 2009, up from £87.2 million in 2008, on which the company will pay just 12% income tax after it re-domiciled its holding company to Ireland. February 10, 2010
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Stig Sollund, director general, tax law department at the Ministry of Finance in Norway answers TPWeek's questions. February 10, 2010
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Under pressure from countries who view Ireland as a soft touch for aggressive tax planning, Ireland has introduced new transfer pricing rules in its new Finance Bill. February 05, 2010
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The European Court of Justice (ECJ) has upheld a discrepancy in Belgium’s transfer pricing rules, even though it represents a restriction on the EU freedom of establishment. February 03, 2010
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Under pressure from countries who view the country as a soft touch for aggressive tax planning, Ireland will probably introduce new transfer pricing rules tomorrow when the Finance Bill 2010 is published. The Bill will implement changes announced in the budget in December. February 03, 2010
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Eduard Sporken and Paul Kraan of KPMG Meijburg & Co explain the changes made to the European arbitration convention. February 01, 2010
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The proposed revisions to chapters I-III of the OECD transfer pricing guidelines have been largely welcomed by transfer pricing practitioners, who feel they address more accurately the business environment. January 27, 2010
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Taxpayers and advisers believe yesterday’s discussion document on controlled foreign companies reflects a genuine attempt by the UK tax authorities to respond to their concerns. January 27, 2010
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A document for discussion on the new UK CFC rules will be published by Her Majesty's Treasury and Her Majesty's Revenue and Customs on Tuesday. January 25, 2010
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International Tax Review will present its fifth annual European Tax Awards at the Dorchester Hotel in London on May 18 2010 January 20, 2010
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Chemical company Innospec Limited has signed a £3.9 million ($6.5 million) agreement with HMRC in settlement of transfer pricing disagreements. January 18, 2010
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Hopes are high that more straightforward transfer pricing legislation will be enacted as part of the tax reforms expected in March this year. January 14, 2010
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A mutual agreement procedure (MAP) for transfer pricing adjustments has been established between the Isle of Man and Australia. January 13, 2010
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Google, the internet search and software company, should expect an investigation from the UK tax authorities after it used transfer pricing to avoid corporation tax, a leading specialist has said. January 06, 2010
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As a new decade approaches, Aaron Leslie and Liz Tookey of TP International discuss what can be expected from world markets and the demand for transfer pricing specialists. January 06, 2010
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Tax authorities across the world are increasing their transfer pricing resources, issuing more penalties and preparing for a greater number of disputes, says a report by a leading tax advisory firm. December 18, 2009
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The Dutch deputy minister of finance has proposed a new law that would make losses from permanent establishments no longer deductible from a company’s worldwide profit. December 16, 2009
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Cameron McKenna has continued the trend of law firms hiring transfer pricing expertise. December 07, 2009
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Recently new draft tax law provisions have been filed with the Belgian Parliament (Parl St, Kamer, 2009-2010, nr 52-2278/001) for further discussion. December 07, 2009
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Recent tax changes announced in the Netherlands budget will not affect transfer pricing, but intangibles have become a target for tax authorities November 26, 2009
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The OECD has released a revised discussion draft for a new article seven of its model tax convention, which relates to permanent establishments November 26, 2009
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The test claimants in the UK thin-capitalisation group litigation against HM Revenue & Customs have won their challenge in the High Court in London that the rules infringed the freedom of establishment article of the European Treaty. November 19, 2009
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Wendy Nicholls and Leela Murugasu of Grant Thornton investigate how deep taxpayers must dive to find suitable comparables today. November 17, 2009
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The OECD has released statistics on the mutual agreement procedure (MAP) caseloads of all member countries for the period of 2006 to 2007. November 11, 2009
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Garrigues has appointed three new international tax and transfer pricing partners. November 11, 2009
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New transfer pricing document requirements in Hungary are compliant with EU guidelines and may also simplify procedures for companies active in member states. October 29, 2009
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Transfer Pricing Associates, a leading independent provider of global transfer pricing and valuation services, formed a strategic alliance with a Canadian consultancy October 23, 2009
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New reporting obligations in financial accounts for intercompany transactions and off-balance arrangements and the increasing use by the tax authorities of disclosures in FIN 48 reports to select taxpayers for transfer pricing audits, have complicated companies’ tax affairs in Belgium October 20, 2009
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The Danish tax authorities have recently issued new administrative guidelines on valuation and documentation of intellectual property (IP) transactions. October 15, 2009
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The Administrative High Court of Austria has said that a precise and detailed description of the nature and market value of all intercompany services rendered to a domestic recipient is required for the fee paid for those services to be tax deductible. October 14, 2009
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Poland has updated its transfer pricing laws with the issuance of two new decrees October 14, 2009
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The Turkish Revenue released guidelines on its form of mutual agreement procedure (MAP) on July 31. Advisers expect the process to become increasingly popular in the country. October 07, 2009
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In general, extensive documentation has to be prepared to demonstrate the application of the benefit test. Will the EU Joint Transfer Pricing Forum provide guidance for simplifications? October 06, 2009
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Alexander Voegele and Hendrik Fuegemann of NERA Economic Consulting outline how new administrative guidelines are affecting taxpayers’ application of the relocation of functions regulations in Germany October 01, 2009
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The number of completed mutual agreement procedures is increasing among OECD countries, new statistics have revealed October 01, 2009
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Service transactions are the source of numerous transfer pricing disagreements between taxpayers and tax authorities, a panel of transfer pricing experts has said October 01, 2009
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The economic crisis means tax authorities are conducting more audits to boost revenues. More companies are challenging adjustments, leading to a rise in controversy September 24, 2009
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Companies are changing their transfer pricing structures to deal with the global economic downturn, both to accommodate changes in the business situation and adapting to extra pressure from tax authorities. September 24, 2009
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The complex procedure and uncertainty of the arbitration system in France led to some heated debate at the Global Transfer Pricing Forum September 23, 2009
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More information has been released on France’s new transfer pricing documentation requirements September 23, 2009
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The future of the arm’s-length principle looks certain, as there is no viable alternative available, the head of the OECD's transfer pricing unit has said September 23, 2009
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Companies must be prepared to divulge more information for transfer pricing audits than in other similar situations, said panellists at the Global Transfer Pricing Forum September 23, 2009
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The head of the OECD's transfer pricing unit told a conference in Paris today that she and her colleagues were discussing whether a project on intangibles should be part of the next work programme of the organisation's Centre for Tax Policy and Administration.
September 22, 2009
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The European Commission has proposed a revision of the code of conduct for applying the arbitration convention (AC) in a bid to strengthen the measure that acts to prevent double taxation in transfer pricing cases in the EU September 17, 2009
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If a German affiliate of a MNE receives administrative services (for example tax, legal and accounting advice) from a foreign holding corporation what formal requirements must be met under German rules? And how do the services provide a benefit for the German company? September 16, 2009
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The OECD has released a proposed revision of several important chapters of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
September 14, 2009
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The lengthy process involved in arbitration matters, sometimes taking up to six years to reach a resolution needs to be changed, says a leading adviser. September 09, 2009
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Transfer pricing has never been under so much scrutiny from taxpayers and tax authorities. Profits and, consequently, tax receipts are dwindling, as the recession in the global economy has put company balance sheets and national revenues under extreme pressure September 03, 2009
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DLA Piper has appointed two KPMG economists to join its Amsterdam office as transfer pricing specialists August 24, 2009
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An expert panel at International Tax Review’s global TP forum in September will look at how companies deal with US cost sharing rules and compare them with similar rules in other countries. August 19, 2009
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TP International ponders the effect of the economic downturn on recruitment in transfer pricing August 18, 2009
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An expert panel at International Tax Review’s Global TP Forum in September will look at the best way to handle tax controversy and alternatives to litigation. August 12, 2009
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One of the French government's senior advisers on taxation will give a keynote address at International Tax Review's Global Transfer Pricing Forum in Paris next week August 12, 2009
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The introduction of new transfer pricing documentation rules has led to taxpayers facing more frequent and detailed audits of their activities than ever before. August 12, 2009
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Werner Stuffer and Susann van der Ham of PricewaterhouseCoopers in Germany discuss the increase of large transfer pricing audits in Germany August 11, 2009
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In today’s environment, multinational companies are more than ever looking for ways to use taxation laws to help buoy their finances. August 06, 2009
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Efforts made by one UK crown dependency to enhance its network of international tax treaties have been bolstered this week by the signing of an agreement that includes transfer pricing provisions. July 29, 2009
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A proposal from the Netherlands government makes it even more important for companies to have sufficient documentation in place to support the arm’s-length nature of inter-company financial transactions between Dutch and non-Dutch group companies. July 22, 2009
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Transfer pricing theory has long been associated with transactions within multinational companies, but now it is being applied to the exchange of football players between English football [soccer] clubs. July 22, 2009
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Werner Stuffer and Jörg Hanken of PricewaterhouseCoopers discuss German business restructuring regulations and how the economic crisis affects this area of tax planning. July 21, 2009
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The Swedish Administrative Court of Appeal has upheld a lower court decision clarifying the determination of the arm’s-length interest rate for intercompany loans in a case involving one of the country’s largest real estate companies. July 15, 2009
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Norbert Raschle, Nicolas Bonvin and Mohamed Serokh, PricewaterhouseCoopers July 14, 2009
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The general headquarters of the Italian Tax Police have issued a circular letter aimed at providing tax officers with updated instructions on the assessment activities they should perform. July 08, 2009
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A Polish contract manufacturer for Plastic AG, a German entrepreneur, delivers the final goods directly to a customer. Now Polish SA takes over and invoices the customer. Does this trigger any German taxes? July 08, 2009
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The UK government is asking for public opinion on new capital gains rules for groups of companies. July 08, 2009
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Freshfields Bruckhaus Deringer gives Danny Beeton the nod as the firm’s head of transfer pricing economics. July 01, 2009
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Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers. July 01, 2009
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Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation. June 30, 2009
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Authors of a report on tax havens and development, commissioned by the Norwegian government, believe international action is required to deal with the problem of transfer mispricing. June 30, 2009
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The Amsterdam Court of Appeals hands victory to the taxpayer in a transfer of goodwill dispute, limiting the taxes payable. Eduard Sporken, and Jenny Theresia of KPMG discuss the case and its implications. June 23, 2009
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For companies that use transfer pricing to avoid paying tax, news that country-by-country reporting is on the agenda of a meeting of G20 finance ministers in Berlin next week is bad news. June 17, 2009
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Danny Beeton and Hannah Carter of Grant Thornton in the UK explain how the decision in the DSG case is potentially a turning point in transfer pricing economics, at least in the UK June 17, 2009
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Control over risk quickly became a significant point of discussion during a two-day public consultation on the transfer pricing aspects of business restructuring at the OECD in Paris this week June 11, 2009
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The Polish ministry of finance has published a document which identifies areas of possible tax fraud to be investigated, with the aim of raising revenues by catching the cheats. One of the priorities is transfer of income to related parties. June 10, 2009
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Following the conclusion of HM Revenue and Customs first major successful transfer pricing dispute, UK taxpayers are being warned that the authorities are thirsty for more. June 10, 2009
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Diane Hay has been appointed international tax special adviser at PricewaterhouseCoopers in the UK May 21, 2009
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International Tax Review announces the winners of the European Awards 2009. May 20, 2009
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The Greek tax authorities have issued a circular that drives home the message to taxpayers that transfer pricing documentation is of extreme importance. May 18, 2009
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Transfer pricing rules in France face a dramatic overhaul, with stringent new documentation requirements and increased scrutiny on taxpayers expected. May 13, 2009
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Taxpayers might one day rely on a standardised set of documentation, prepared centrally, that is valid for all jurisdictions in which the company operates. But for now, advisers say companies must still be aware of regional differences. May 13, 2009
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Susan George, board chair of the Transnational Institute, a worldwide fellowship of scholar activists, has slammed transfer pricing for being a hindrance to institutions such as the IMF providing financing to emerging nations. May 06, 2009
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Mark Atkinson and Richard Coombes of Deloitte in London believe that the decision in the first UK transfer pricing case in more than 20 years shows that taxpayers need a good reason to base a transaction in a low-tax jurisidiction May 01, 2009
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The Austrian Ministry of Finance discussed the appropriate interest rate when a group financing entity is located in a foreign low tax country in its annual tax meeting, meaning potential changes for taxpayers. April 28, 2009
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In a welcome move for multinational companies, the UK chancellor announced he will simplify the corporate gains rules for notional transfers within a group of companies April 23, 2009
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A UK company has been told that it has breached transfer pricing rules, but is unsure just how much it will have to pay HM Revenue and Customs April 23, 2009
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The Danish tax authorities are demanding DKr3.6 billion ($637 million) in back taxes from a multinational company that it claims used aggressive transfer pricing to avoid paying the proper amount of tax April 15, 2009
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Ireland will introduce a tax relief scheme for the acquisition of intellectual property, the country’s finance minster announced yesterday in his supplementary budget speech April 08, 2009
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The UK tax authorities have amended draft legislation that will change the corporation tax rules on late-paid interest between connected companies, following initial public response to the proposal March 25, 2009
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Russia is hurriedly drafting new transfer pricing rules, five years after the reform was initially proposed March 25, 2009
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A Turkish construction company has won a case in Russia over when a permanent establishment (PE) is created.
March 19, 2009
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International Tax Review is conducting a poll to find the 10 most admired tax directors in Europe. March 19, 2009
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Latvia’s tax authorities are becoming more aggressive in their approach to transfer pricing and companies need to be better prepared, a tax lawyer has warned. March 16, 2009
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It borders on the trite to say that a company still needs to deal with its tax affairs whether it is making or losing money March 11, 2009
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Jersey and the UK signed a tax information exchange agreement today in London March 11, 2009
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The public comments in response to the OECD’s discussion draft on the transfer pricing aspects of business restructuring have been published on the Organisation’s website.
March 11, 2009
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The Czech Republic looks set to revert to thin-capitalisation rules that existed in 2007 after a vote in the lower house of parliament on Tuesday. March 04, 2009
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The UK’s direct tax law was altered yesterday, as a new draft bill rewriting transfer pricing guidelines was published, though it did not deliver any substantial changes. March 04, 2009
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Transfer Pricing International is the leading global specialist in transfer pricing recruitment around. Launched over 12 months ago by Aaron Leslie and Liz Tookey, the firm has successfully completed assignments in over 30 countries across Asia, the Americas and Europe. March 03, 2009
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A prominent UK newspaper ran a two-week expose on transfer pricing and international tax planning recently, attempting to name and shame some of the world’s leading multinational corporations. Aaron Leslie of TP International says the reaction was simplistic March 03, 2009
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Taxpayers were warned of the UK government’s dual approach to disregarding transactions at a transfer pricing conference in New York last week. February 10, 2009
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Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HM Revenue & Customs in the UK tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority, offers taxpayers an insight into how transfer pricing cases are selected and talks about the future of transfer pricing. February 05, 2009
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The new office that NERA Economic Consulting, a global provider of economic advice and analysis in business, legal, and regulatory matters, is opening in Geneva will focus on transfer pricing and intellectual property services February 04, 2009
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TPA Global has made up a partner in their customs practice in Switzerland. January 28, 2009
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Her Majesty’s Revenue & Customs (HMRC) is expected to change the penalties it imposes on erroneous transfer pricing documentation from April. It is thought that the minimum penalty applied will be 10% of the total tax lost to HMRC although the total penalty will depend on the severity of the error. January 21, 2009
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Edward Morris has left HM Revenue & Customs in the UK to join the tax team at Deloitte. January 21, 2009
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A tax dispute between global pharmaceutical firm, AstraZeneca, and HM Revenues and Customs (HMRC) has been deferred until April 2010, with the outcome of the case expected to have an impact on multinationals and their transfer pricing regimes.
January 20, 2009
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Taxpayers, officials and practitioners can contribute to the debate on business restructuring at a conference in London on February 13, six days before the closing date for comments on the OECD's discussion draft January 15, 2009
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Deloitte in Luxembourg has launched a new transfer pricing practice led by new hire Marc Rasch and partner Erwan Loquet January 07, 2009
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Taxpayers may have to explain why they used a certain exchange rate in related-party transactions. If they cannot they could face higher tax bills, explain Jarosław Bieroński and Bartłomiej Biały of Sołtysiński Kawecki & Szlęzak December 23, 2008
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Stephanie Pantelidaki will join KPMG’s transfer pricing team in London as an associate partner December 22, 2008
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HM Revenue and Customs in the UK has released draft legislation that amends the corporation tax rules on late-paid interest between connected companies. December 16, 2008
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The amendment to the Polish Accounting Act of March 18 2008, part of which came into force on August 22 2008, has changed the scope of information and data to be provided in additional information to the financial statements December 15, 2008
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Diane Hay has left HM Revenue and Customs December 11, 2008
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On November 24 2008 the Polish President signed the act of November 6 2008 amending (among other things) the corporate income tax act. The new act introduces regulations concerning transfer pricing issues that will allow taxpayers to eliminate double taxation in transactions concluded with their foreign related parties. December 10, 2008
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Angelika Thies of CMS Hasche Sigle in Munich, Germany explains the latest developments in German transfer pricing December 10, 2008
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A London event in February gives taxpayers the opportunity to contribute to the debate on the OECD's discussion draft on business restructuring December 10, 2008
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Following an amendment to the draft law entitled “Market Supervision Authority and other provisions” submitted to the Greek parliament, rules are being introduced for auditing transfer pricing in inter-company transactions. The rules are based on the OECD arm’s length principle December 04, 2008
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Greece has introduced new laws to bring its transfer pricing documentation legislation more into line with OECD standards December 03, 2008
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HM Revenue and Customs is to introduce corporate tax legislation that amends the loan relationships rules affecting connected companies December 03, 2008
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Diane Hay, chairwoman of Her Majesty’s Revenue & Customs’ transfer pricing board at HMRC would like to halve the amount of transfer pricing cases that HMRC takes up, concentrating resources on higher risk cases November 26, 2008
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Slovakia and Spain have both introduced amendments to bring their legislation into line with the EU transfer pricing forum’s approach to documentation. November 26, 2008
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The OECD held a consultation on November 19 2008 with business commentators on the topics of comparability and profits under OECD transfer pricing guidelines for multinational enterprises and tax administrations November 26, 2008
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The French tax administration is increasingly turning to the transactional net margin method of determining an arm's length price. Jean-Luc Trucchi argues that rapidity and efficiency should not be used as an excuse for using a simplistic method that may generate a biased application of the arm’s length principle. November 21, 2008
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In France, the concept of marketing intangible assets has led the tax authorities to imposing taxes on companies. Jean-Luc Trucchi explains what is happening. November 18, 2008
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The House of Commons public accounts committee report on the management of large business corporation tax stated that half the growth in global trade comes from transactions between subsidiaries of multinational companies October 28, 2008
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Leslie Van den Branden of De Witte Viselé Associates explains the environment of transfer pricing audits in Belgium October 28, 2008
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The fact that Italy criminalises transfer pricing conflicts was a major example used to demonstrate the problems with asking tax practitioners to comply with all tax laws around the world October 28, 2008
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Sweden tightens transfer pricing regulation October 28, 2008
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Ebrahim Ali, has joined PricewaterhouseCoopers Legal's tax litigation team October 14, 2008
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The Netherlands has issued a new mutual agreement procedure (MAP) in a move that will make avoiding double taxation more accessible and transparent for taxpayers.
October 08, 2008
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Eduardo Goldszal, a partner at KPMG in Portugal highlights the main points of the country’s new APA legislation September 19, 2008
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Ramazan BİÇER, senior transfer pricing specialist in the Transfer Prising Division of the Turkish Revenue Administration, describes the regime for transfer pricing documentation in Turkey September 04, 2008
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Peter Andersen of Transfer Pricing Associates highlights the contrast in the results for two taxpayers from Danish litigation over the use of price quotes in transfer pricing September 02, 2008
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Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process September 02, 2008
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Ramazan BİÇER, senior state revenue specialist of the Turkish Revenue Administration, discusses an amendment to transfer pricing law in Turkey that deals with the loss of tax revenue to the National Treasury August 28, 2008
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In less than a month, leading transfer pricing personalities from all over the world will be gathering in Rome for International Tax Review's 8th Global Transfer Pricing Forum. August 28, 2008
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Jarosław Bieroński and Bartłomiej Biały, of Sołtysiński Kawecki & Szlęzak, believe taxpayers should prepare contemporaneous transfer pricing documentation as the tax authorities may ask for them August 26, 2008
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Key jurisdictions such as Belgium, China, Luxembourg and the US appear in the UK's tax treaty work plan over the next eight months August 20, 2008
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A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP Week.com lists more than 350 cases.
August 07, 2008
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The UK tax authorities have proposed amendments to corporation tax rules on late payments of interest between connected companies August 07, 2008
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Italy is waiting to see if controversial changes made to the taxation of stock options, which could affect the Italian subsidiaries of foreign based parent companies, will be made permanent by the government. July 30, 2008
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Courtney Fowler of PricewaterhouseCoopers says Kazakhstan needs to change its policy, for example, regarding international agreements and international disclosure, if it is to make it into the WTO July 17, 2008
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Billions of dollars are at stake in transfer pricing disputes waiting to be resolved through the European Commission’s Arbitration Convention process July 14, 2008
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Jaroslaw Bieronski and Bartlomiej Bialy of Soltysinski Kawecki & Szlezak highlight the transfer pricing methods allowed in Poland July 14, 2008
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Romania and Bulgaria have joined the European Commission's Arbitration Convention. The two EU member states acceded to the process on July 1. July 09, 2008
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In the first in a series of keynote articles on the European Union Joint Transfer Pricing Forum, EUJTPF member Dirk van Stappen discusses its current focus June 26, 2008
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New guidance establishes rights and responsibilities of taxpayers June 19, 2008
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Medical devices business faces higher tax bill over Irish subsidiary June 12, 2008
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Maarten Koper and Susanne Verloove of Ernst & Young in Limassol on the interaction between tax treaties and transfer pricing rules in Cyprus June 04, 2008
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Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008
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Inter-company services charges again under the transfer pricing spotlight May 27, 2008
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Ludger Wellens and Irina Gerner of PricewaterhouseCoopers, TP Week’s correspondent in Germany, see potential disputes emerging May 21, 2008
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Former Cadbury Schweppes and Andersen tax man is specialist in APAs
May 19, 2008
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Polish authorities step up scrutiny of related party documents in transfer pricing sweep May 15, 2008
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Natalia Valkovskaya, transfer pricing senior manager at KPMG in Moscow, describes the Russian government’s thinking May 12, 2008
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Multinationals in Russia face more onerous documents regulation
May 08, 2008
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Zheng Li and Ted Keen, of CRA International’s London transfer pricing practice, argue that taxpayers can anticipate greater scrutiny May 01, 2008
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Finance ministry to issue circular letter to industry and tax profession April 30, 2008
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Spot checks by Finnish tax authority on transfer pricing documents anticipated by advisers April 24, 2008
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Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year April 24, 2008
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Swedish Tax Agency proposal covers bilateral and multilateral APAs April 22, 2008
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Felipe González Martín, of TP Week correspondent firm Garrigues, reports on a critical development for transfer pricing in Spain April 16, 2008
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Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta April 15, 2008
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Spanish National Court sets standard for intra-group services evidence April 14, 2008
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Government aims to align requirements with other European countries April 07, 2008
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Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process April 07, 2008
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Practice appoints Luis Castillo for Spain and Latin America March 25, 2008
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Former Big Four and IRS intangibles expert takes up new role in London March 20, 2008
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Tynwald endorses seven-country package including transfer pricing agreements March 19, 2008
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David Ive quits Mayer Brown for leading UK-based law firm's City funds practice March 19, 2008
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Manuel Ángel Bouzas, of TP Week correspondent Garrigues, describes the process towards a new transfer pricing policy March 17, 2008
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Dunja Hitrec, of Ernst & Young in Zagreb, looks at the Croatian tax authority’s approach to transfer pricing auditing March 15, 2008
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Lucijan Klemencic, of Ernst & Young in Ljubljana, reports on the regime for transfer pricing audits in Slovenia March 15, 2008
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Hedvig Solyomvari, of Ernst & Young, reports on the climate for transfer pricing audits in Hungary March 14, 2008
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Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008
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Joan Hortalà, tax partner, and Neus Mollera, associate, of leading Spanish law firm Cuatrecasas Abogados explain the environment for transfer pricing audits in Spain March 14, 2008
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Marius Leivestad and Eivind Falck-Ytter, Ernst & Young in Oslo, examine the new Norwegian transfer pricing documentation rules March 14, 2008
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Monique van Herksen, a principal in Baker & McKenzie in Amsterdam, outlines the Dutch approach to transfer pricing documentation March 10, 2008
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Dunja Hitrec, of Ernst & Young in Zagreb, gives a detailed assessment of Croatia's transfer pricing documentation rules March 01, 2008
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Ramón López de Haro and Javier Montes Urdín of TP Week correspondent firm Garrigues argue that new rules will make APAs more popular March 01, 2008
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Key development of island's transfer pricing regime expected in 2008 February 29, 2008
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Mike Ahern and Sebastian Lebda, of PwC in Poland, summarise the Polish transfer pricing documentation rules February 27, 2008
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Maarten Koper and Susanne Verloove, of Ernst & Young in Cyprus, discuss the regime for transfer pricing documentation
February 26, 2008
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Davide Bergami and Gianluca Nieddu, of Ernst & Young in Italy, outline the Italian transfer pricing documentation rules February 26, 2008
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Katarina Kuuskoski and Bo Lindqvist of Baker & McKenzie in Stockholm give a detailed account of the documentation environment in Sweden February 25, 2008
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Libor Frýzek and Jiří Teichmann, of Ernst & Young in Prague, describe the environment for transfer pricing documentation in the Czech Republic February 22, 2008
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Comprehensive order issued this week to implement documents law February 21, 2008
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Artur Klesk, head of transfer pricing at Accreo Taxand, a leading Polish TP commentator, discusses the fortunes of the APA initiative February 14, 2008
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Mario Ortega Calle, of TP Week correspondent Garrigues, explains how the regulation of intra-group expenses has changed February 13, 2008
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Joan Hortalà and Neus Mollera from Cuatrecasas Abogados set out key changes to transfer pricing and explain how they impact policy on documentation February 12, 2008
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Andreas Köster-Böckenförde , of Jones Day in Frankfurt, explains the thinking behind recent revisions to TP law February 05, 2008
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Provided by DLA Piper January 31, 2008
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Supplied by DLA Piper January 31, 2008
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Provided by DLA Piper January 31, 2008
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Intra-company transactions must reported for fiscal 2007 January 24, 2008
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PricewaterhouseCoopers interprets recently updated rules January 19, 2008
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US transfer pricing agreement - backdated to 2003 - at core of inquiry January 10, 2008
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UK tax authority introduces plan to cut decision times January 07, 2008
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TP Week published its list of most aggressive tax authorities list last week. The No 10 position was occupied by the HMRC December 20, 2007
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Deloitte UK analyses the HMRC’s statement of practice on advance thin capitalisation agreements. Michael Gordon-Brown and Ian Clarke report December 19, 2007
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TP Week correspondent Taj conducts a survey of 430 decision-makers in companies in France December 18, 2007
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Changes will broaden the base of the thin capitalisation regime December 15, 2007
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Team leader Teshome is poached from Grant Thornton, team from KPMG December 11, 2007
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UK revenue issues statement of practice and model agreement December 06, 2007
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Italy’s tough TP policy encourages more corporate deals. PwC reports December 05, 2007
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Tax authority focuses on audits and APAs, reports PwC November 22, 2007
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The Belgian tax authorities have reformed the state's dispute resolution approach. PwC reports. November 19, 2007
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Gianmarco Monsellato and William Finan, at TP Week sponsor Taj, argue for a policy change on intra-group interest rates November 14, 2007
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Gianmarco Monsellato and William Finan, at TP Week sponsor Taj, argue for a policy change on intra-group interest rates November 14, 2007
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Chiltern's head of transfer pricing rejects BDO for new firm November 14, 2007
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PricewaterhouseCoopers comments on the transfer pricing policy of the German tax authorities November 12, 2007
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John Neighbour runs a team of 80 UK-based transfer pricing specialists for KPMG. He was formerly head of transfer pricing at the OECD November 08, 2007
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José Luis Gonzalo, Ramón Palacín, Juan José Terraza, Carlos Gabarró, Eduardo Sánchez and Vanessa Hernández of Ernst & Young in Spain analyse the regulations take effect in 2008 November 01, 2007
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Belgium's transfer pricing regime has become stricter, reports PwC October 31, 2007
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Finland introduced new transfer pricing legislation, says PwC October 31, 2007
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Short deadlines characterise transfer pricing audits October 31, 2007
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A radical revision of transfering pricing policy in Germany is described by PwC October 31, 2007
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PwC reports on Ireland's approach to transfer pricing regulation October 31, 2007
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PwC analyses the regulation of transfer pricing in key European markets October 31, 2007
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PwC describes how the Spanish government has taken its transfer pricing approach up a step October 31, 2007
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HMRC wants to be seen as arbiter of best practice, says PwC October 31, 2007
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Transfer Pricing Solutions, a UK-based boutique transfer pricing consultancy, has recruited Peter Male from Ernst & Young. October 24, 2007
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In the first part of an interview with TP Week, Roy Warden, one of the senior members of HMRC’s transfer pricing management, looks at the challenges ahead
October 19, 2007
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Rosa Maria Soares, transfer pricing partner at Deloitte in Lisbon, describes plans for advance pricing agreements in Portugal October 19, 2007
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Substantial changes to the Russian transfer pricing regime will be debated by parliament in late November. October 18, 2007
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The government has announced a series of key changes to transfer pricing rules which take effect on January 1 2008. October 17, 2007
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Pan-European Group begins focus on transfer pricing implications of business reorganisations October 17, 2007
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Theo Elshof and Pim Gerritsen van der Hoop, of Deloitte in the Netherlands, writing exclusively for TP Week, examine the TP priorities for the Dutch tax authorities October 17, 2007
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Mike Ahern, of PwC Poland, examines revenue authority policy on transfer pricing in Poland October 15, 2007
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By Rainer Eidemiller and Priit Lätt of Glimstedt Straus & Partners in Tallinn writing exclusively for TP Week October 12, 2007
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The UK tax authorities are changing the way they deal with transfer pricing. So International Tax Review presents the findings of a major and timely survey of corporate taxpayers on this increasingly important subject. October 08, 2007
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Peter Oszkó and Annamária Kőszegi of Deloitte in Budapest report on how the tax authorities have become tougher September 27, 2007
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HMRC seeks the view of big business on its transfer pricing recommendations September 27, 2007
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Craig McAree is poached from Grant Thornton to launch new team September 26, 2007