Menu toggle Menu toggle

Navigation Menu


Which member of the BRICS has the most developed TP regime?

South Africa

View previous poll results

Skip to Navigation menu Skip to top of page



Australian Treasurer introduces new law to target foreign multinationals

The out-going Australian Treasurer, Joe Hockey, has made good on promises to introduce new laws to target aggressive multinational tax avoidance. Effective from January 2016, the new law could apply to 1000 multinational taxpayers. October 02, 2015

Europe aims to lead the world in transfer pricing legislation

The OECD has been leading the discussions on global transfer pricing issues through its BEPS project but, as this draws to a close, the implementation of BEPS-influenced legislation is producing different interpretations globally. October 01, 2015

China wants local version of BEPS

China’s State Administration of Taxation (SAT) has released a discussion draft circular, which would see the implementation of the OECD three-tier reporting style of county-by-country-reporting (CbCR) as well as the master and local file. October 01, 2015

New Zealand updates APA programme

New Zealand Inland Revenue (IR) has updated its guidance on advanced pricing agreement (APA) applications. The process has not been formalised however. October 01, 2015

Why tax authorities also need to upgrade their technology for CbCR

Meeting new reporting requirements needs technology planning for taxpayers and revenue authorities alike, a panel at International Tax Review and TPWeek’s Global Transfer Pricing Forum in Washington DC concluded. September 28, 2015

Oil price downturn brings increased transfer pricing audits

In the second half of 2014 oil prices sharply fell. One year on and the markets seem unlikely to return to the former high, at least in the next few years. September 22, 2015

Infogain’s profit-split method approved by ITAT

The income tax appellate tribunal (ITAT) in Delhi upheld Infogain India’s appeal against the deputy commissioner of income tax’s (DCIT) TP adjustment. ITAT found that the use of the profit split method (PSM) was valid considering Infogain’s value chain. September 21, 2015

Netherlands introduces CbCR

The Netherlands has become the latest country to introduce draft legislation for country-by-country reporting (CbCR) alongside requirements for a master file and a local file. September 21, 2015

Prepare for BEPS: How to find evidence of independent party deal structures

It is no longer sufficient to only support the arm’s-length pricing of transactions. Companies must now validate the structure of their intercompany transactions against evidence from independent party transactions. September 14, 2015

IRS significantly changes competent authority application

The IRS has published final changes for taxpayers applying for competent authority (CA) assistance. An IRS official and a former US Competent Authority explain what this means for taxpayers. September 14, 2015

Why smaller companies are at a greater risk of TP adjustment from HMRC

Through analysing HM Revenue and Customs’ (HMRC) “tax under consideration” figures it appears HMRC is turning its attention to medium sized companies, after years of putting large businesses’ transfer pricing activities in the spotlight. September 09, 2015

How public reporting of corporate tax affairs is becoming more likely

A fundamental sticking-point of country-by-country reporting (CbCR) is that companies’ tax affairs could be published in the public sphere. This is causing a great deal of distress for multinationals concerned about confidentiality and competition. There is consequently a big debate about how to comply and whether companies should comply at all. September 09, 2015

Managing the transfer pricing of intangibles in the oil and gas sector

Intangible assets in the oil and gas industry have become incredibly valuable. Taxpayers need to understand how to manage compliance to mitigate their transfer pricing risks. September 08, 2015

IRS revamps APA procedures

The IRS has finalised changes to its APA procedures, first proposed in November 2013. The changes include greater disclosure requirements for taxpayers but many changes simply formalise existing practices. September 02, 2015

Why India rejected the OECD’s mandatory arbitration plans

India has rejected the OECD’s plans for mandatory arbitration and, despite the country’s non-member status, the proposal has now been dropped. September 02, 2015

Angola focusing on large taxpayers’ transfer pricing

Angolan tax authorities are notifying large taxpayers that have failed to file transfer pricing documentation they will be fined. September 02, 2015

Why alleviation of double taxation is not keeping pace with BEPS work

Taxpayers are becoming concerned the OECD’s aim to alleviate double taxation is being out-paced by the BEPS work. Isabel Verlinden, Patrick Boone, Gaby Bes, and David Swenson of PwC explain why this concern is justified. November 26, 2014

Consensus over definition of intangibles and location savings increasingly unlikely

Action 8 of the OECD’s BEPS project on the transfer pricing aspects of intangibles aims to achieve universal consensus over definition. However, this is beginning to look like an impossible task, with influential BRIC countries such as India, making their own interpretations. December 10, 2014

Asia transfer pricing special focus

Transfer pricing in Asia is a rapidly developing market for taxpayers, their advisers and the authorities. TPWeek held its third annual Global Transfer Pricing Forum in Singapore on December 2&3 with a record turn-out from delegates and featuring two keynote speeches from OECD officials. December 17, 2014

China’s APA stats show acceptance of different TP methods

China’s State Administration for Taxation (SAT) released its advance pricing agreement (APA) statistics for 2013 on December 5 2014. January 12, 2015

Taxpayers criticise Chinese regulations

China’s transfer pricing regulations, which were published on January 9, will affect how companies manage their tax affairs and add to their compliance costs, say tax directors February 11, 2020

New transfer pricing partner at PwC Ireland

June 18, 2015

DLA Piper boosts TP practice from London office

June 17, 2015

Andersen Tax boosts TP department in US

June 10, 2015

Transfer pricing attorney joins Baker & McKenzie

Transfer pricing attorney, Barbara Mantegani, has joined Baker & McKenzie’s Washington DC tax practice as counsel. April 08, 2015

Schoeneborn joins EY from Merck

Dr. Frank Schoeneborn joins EY as a partner in EMEIA Tax Centre focusing on intercompany effectiveness and operational transfer pricing. March 27, 2015

Singapore updates its transfer pricing guidelines

The Singapore revised transfer pricing (TP) guidelines, published January 6 2015, require taxpayers to prepare and maintain contemporaneous TP documentation to support TP positions and have this in place by the time the company’s tax return is filed. January 19, 2015

New TP reforms in Ukraine likely to ramp up disputes and prolong audits

The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pricing control. January 14, 2015

China focuses on cross-border transactions in war on tax evasion

The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. The move signals a crackdown on profit shifting, which could see cross-border transactions increasingly scrutinised. January 12, 2015

Lack of transfer pricing rules leads to questionable audits in Hong Kong

Despite a self-touted reputation as a leading global financial centre, Hong Kong’s Inland Revenue Department (IRD) has been criticised by tax practitioners for overly aggressive audits on asset managers. Hong Kong has limited transfer pricing legislation and often seeks to enforce arm’s-length pricing through practice notes and a network of tax treaties. January 08, 2015

The transfer pricing implications of the Italian regional tax on productive activities

The provincial tax court of Reggio Emilia has issued ruling No 510/03/14 relating to the Italian regional tax on productive activities (IRAP). January 06, 2015

Reduction in maximum income tax rate for inclusion in Brazil’s black and grey lists

The Brazilian Ministry of Finance has issued Portaria MF no. 488/2014, on December 1, which reduced the maximum income tax rate from 20% to 17% for the purposes of applying the concepts of tax havens and privileged tax regimes. December 08, 2014

Swedish Tax Agency reviews TP legislation and proposes changes

The Swedish Tax Agency has, on request by the Swedish Government (Ministry of Finance), evaluated the transfer pricing documentation rules’ functionality and proposed possible changes to simplify the application. December 08, 2014

The dangers of creating an accidental PE and how to avoid it

As companies’ employees become more globally mobile, there is an increasing risk that a permanent establishment (PE) may occur unintentionally, leaving taxpayers at risk of taxable income liabilities. November 28, 2014

Determining the transfer pricing policy for liquefied natural gas

Tamir Druz, a director at Capra Energy Group, discusses the best methods for determining an optimal transfer pricing policy for liquefied natural gas (LNG). September 01, 2014

Hong Kong signs first bilateral APA

Hong Kong has agreed its first bilateral advance pricing agreement (APA) since its scheme began in March 2012. EY, who facilitated the deal between Hong Kong and the Netherlands, explain how the process progressed with the authorities. July 10, 2014

Marzen Aluminum ruling based on structuring rather than pricing

The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The ruling is significant because it is the first Canadian decision focusing on the structuring of transactions rather than the pricing. June 26, 2014

Netherlands reclaims Swiss company’s profits and applies penalties in transfer pricing case

The Dutch District Court of Zeeland/West-Brabant ruled, on January 17 2014, on a Swiss Captive Insurance company (without employees), taxing most of its profits back in the hands of a related Dutch taxpayer with 50% penalties. March 18, 2014

Intangible assets in the media and entertainment industries: In depth analysis

The US television production industry reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look at dealing with intangibles. February 18, 2014

The transfer pricing considerations of Suzuki’s 100% subsidiary in India

Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implications, which must be considered by any multinational in this position. February 04, 2014

McKesson Canada: CRA wins in Tax Court but taxpayer files with Court of Appeal

The Canada Revenue Agency (CRA) saw pharmaceutical company McKesson’s arguments dismissed by the Tax Court in December 2013 but the company has now filed its arguments with the Federal Court of Appeal. January 24, 2014

How to organise your TP department to avoid dispute

Governments' hard-line approaches to companies' transfer pricing arrangements has resulted in a rise in transfer pricing cases being resolved in court, explains Fabrizio Lolliri, European director of transfer pricing for Hogan Lovells. January 21, 2014

The new cost of global compliance: Private company data for local comparables

All of us in the tax world know that transfer pricing has been a hot topic this year. Around the globe, tax authorities have become more aggressive, primarily to reduce government fiscal deficits. January 20, 2014

UN tax committee publishes draft transfer pricing manual

The UN Committee of Experts on International Cooperation in Tax Matters will consider its draft Transfer Pricing Manual for Developing Countries at its eighth session in Geneva from October 15-19. October 03, 2012

Norway transfer pricing documentation guide

Hans-Martin Jørgensen and Michael Vorndran of Deloitte August 09, 2012

Austria transfer pricing documentation guide

By Andrea Lahodny and Gabriele Holzinger of Deloitte August 08, 2012

Greece transfer pricing documentation guide

By Stefanos Mitsios of Ernst & Young August 08, 2012

Indonesian transfer pricing documentation guide

By Permana Adi Saputra of PB Taxand August 08, 2012

Malaysia transfer pricing documentation guide

By Bernice Tan of Taxand Malaysia August 08, 2012

Denmark transfer pricing documentation guide

Tim Holmes and Thomas Bjerre of Ernst & Young Copenhagen outline the approach to the transfer pricing documentation requirements in Denmark. August 03, 2012

US transfer pricing documentation guide

By Kathrine Kimball and Minjung Kim of Charles River Associates July 26, 2012

UK transfer pricing documentation guide

By Graham Head (Senior Manager) and Liz Hughes (Transfer Pricing Director), Grant Thornton UK July 24, 2012

South Korea transfer pricing documentation guide

By Taehyung Kim of Deloitte July 23, 2012

HMRC is exchanging unilateral APA information with treaty partners

HMRC is exchanging the terms of its unilateral advance pricing agreements (APA) with UK tax treaty partners. The measure is part of the revenue’s drive towards greater transparency and began this month. February 26, 2013

How to survive a transfer pricing audit in India

Hardev Singh and Saurabh Dhanuka, of KPMG, TP Week’s correspondent in India, give practical advice on dealing with India’s revenue authorities May 22, 2008

How to survive a transfer pricing audit in Malta

Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta April 15, 2008

How to survive a transfer pricing audit in the Czech Republic

Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process April 07, 2008

How to survive a transfer pricing audit in China

Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit April 06, 2008

How to survive a transfer pricing audit in Poland

Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008