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Panellists to share dispute resolution experiences

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

Danish tax authorities release tax action plan

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

Taxpayers to seek advice on marketing intangibles

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

Joint Committee‘s budget analysis shows more pro-corporate slant

The report from the Joint Committee on Taxation (JCT) on President Obama's 2011 budget, provides revenue estimates for each of the tax provisions in the budget, including proposals about transfer pricing and treatment of intangibles. August 31, 2010

New keynote speaker announced for Global Transfer Pricing Forum

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

Nominees for Americas Tax Awards unveiled

International Tax Review will present its fifth annual Americas Tax Awards at the Waldorf-Astoria Hotel in New York on September 29 2010. August 25, 2010

CRA continues to grow mutual agreement procedure programme

The Canadian mutual agreement procedure (MAP) programme saw an increase in the number of accepted and completed cases in the past year. August 19, 2010

Authorities make $270 million claim against HP

The Japanese tax authorities have ordered Hewlett-Packard Japan to pay ¥23 billion ($270 million) in unpaid taxes. August 13, 2010

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Australian Tax Office appeals SNF decision

The Australian Taxation Office (ATO) has lodged an appeal to the Full Federal Court of Australia against the recent transfer pricing decision in the SNF case. September 01, 2010

Future of the arm’s-length standard up for discussion

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

New Indian Direct Tax Code spells change

On August 30 2010, the Indian government tabled a Direct Tax Code Bill 2010 in the parliament. The new code aims to replace the Income Tax Act 1961 and the Wealth Tax Act 1957. If enacted, it will be effective from April 1 2012. September 01, 2010

Bilateral advance pricing arrangement signed in Shanghai

After several years of competent authority discussion, a home appliances manufacturer has agreed terms on an advance pricing agreement (APA) with the Chinese tax authorities. August 31, 2010

IRS reorganisation signals more intensive approach to transfer pricing

The Large and Mid-Size Business division of the Internal Revenue Service (IRS) will become the Large Business and International (LB&I) division on October 1 in a move that signals a greater focus on transfer pricing. August 24, 2010

Brazil’s transfer pricing rules v OECD’s guidelines

Tatiana Villani and Anna Cecília Brasil of Machado Associados comment on the main differences between Brazil’s transfer pricing rules and the OECD’s guidelines, and the difficulties and opportunities that this may create for taxpayers. August 17, 2010

Former national coordinator highlights Canadian APA approach

Shiraj Keshvani served until March this year as the chief economist for Canada Revenue Agency’s (CRA’s) competent authority services division and was the national coordinator for the advance pricing arrangement (APA) programme. August 13, 2010


OECD review of guidelines renews debate over arm’s length standard

The OECD will review and revise its transfer pricing guidance on intangibles later this year in an effort to clarify one of the most frustrating and notoriously inconsistent areas of international tax. June 10, 2010

Businesses concerned about new transfer pricing challenges

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

Updated: MAP agreement is logical say advisers

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

Brazilian taxpayers left unsure as to which rules to follow

New transfer pricing rules failed to be passed into law within the Constitutional deadline, creating controversy as to which rule applies to transactions carried out since the beginning of the year. June 07, 2010

The Netherlands and US settle mutual agreement

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

Mumbai tribunal rules on business process outsourcing case

Waman Kale and Vinita Chakrabarti report on a judgment by the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) relating to the information technology, business process outsourcing sector. May 27, 2010

Implications of the MAP resolution in India

K R Girish and Rohan Phatarphekar of KPMG discuss the reported agreement reached by the Indian and US competent authorities. May 26, 2010


Baker & McKenzie hires new Australian partner

The international firm has brought in a solicitor and chartered accountant. August 27, 2010

Baker & McKenzie adds new partner

Russell Young has joined Baker & McKenzie in Chicago as a partner. August 17, 2010

KPMG adds two specialists in DC

KPMG has hired two new practitioners with experience of working for the IRS. August 13, 2010

Simpson leaves ATO

A senior transfer pricing official from the Australian Taxation Office is leaving to rejoin Deloitte after 10 years with the tax authorities. August 04, 2010

PricewaterhouseCoopers promotes transfer pricing director

Yvonne Cypher joined the firm in 1997 and specialises in transfer pricing with a particular focus on business restructuring. July 28, 2010

All change at KPMG

Steven Tseng, China partner in charge and Asia Pacific leader for KPMG’s global transfer pricing services is moving to PricewaterhouseCoopers in China, at the same time as many new appointments are made in the US. July 16, 2010

LECG adds transfer pricing expertise in Europe

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

New partner for PricewaterhouseCoopers in the Czech Republic

David Borkovec has been made a partner in the PricewaterhouseCoopers tax and legal services department in Prague. July 13, 2010

McClellan moves to General Electric

Holly McClellan, a partner of Baker & McKenzie in Chicago, will join the corporate tax group at General Electric as transfer pricing leader, tax counsel, for treasury and capital markets on August 16. July 09, 2010

Miller & Chevalier hires Robert Kirschenbaum

Robert Kirschenbaum has moved from Baker & McKenzie to join Miller & Chevalier Chartered in Washington, DC. July 01, 2010

Patton leaves Ernst & Young

After 21 years with Ernst & Young, Mike Patton is leaving the firm to join DLA Piper. June 30, 2010

Blakes hires two litigators

Canadian law firm Blake Cassels & Graydon has taken two tax litigators from rival McCarthy Tétrault. June 29, 2010

Pendo Advisors adds a valuation specialist

Pendo Advisors, a corporate finance and valuation advisory firm in Chicago, has announced the addition of Dan Bourgeois, who has a tax and transfer pricing background, as a managing director June 29, 2010

Ex-Canada Revenue Agency official talks to TPWeek

Fred O’Riordan, formerly with the CRA, talks about moving into the private sector and reveals his hopes for the future of arbitration between the US and Canada. June 23, 2010

Machado Associados hires former government head of transfer pricing

Elen Orsini has left the Brazilian Federal Revenue Service and joined Machado Associados. June 15, 2010

Akin Gump opens Geneva office

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

Indian firm grows practice

As part of a firm-wide restructuring, Vaish Associates has promoted two transfer pricing associates to salaried partner level. June 11, 2010


Uruguay releases new regulations on transfer pricing

Decree number 392/009 amends and clarifies some of the detailed regulations established by decree number 56/009, which was issued in January 2009. October 05, 2009

German legislation for the relocation of functions explained

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

Transfer pricing and packaging of products

A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of goods purchased by Brazilian legal entities and packed or repacked locally for resale. October 01, 2009

China’s newest documentation challenge: how to defend loss-makers

Loss-making documentation is a catch-22 situation in China. Glenn DeSouza, managing director at Transfer Pricing Management Consulting in Shanghai, which has an exclusive strategic alliance with Baker & McKenzie, explains the difficulties September 17, 2009

Thin capitalisation is on the way to India

India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules September 08, 2009

Spanish authorities target companies with new documentation rules

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


IRS hits taxpayer with $3 billion claim

The US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties September 08, 2009

TPDoctor: Advance pricing agreements in India

What does the introduction of advance pricing arrangements mean for taxpayers in India? September 01, 2009

Vietnam auditors step up transfer pricing challenges

In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing. September 01, 2009

Xilinx wins support from business

In a series of amicus briefs filed with the US Court of Appeals for the Ninth Circuit, several powerful groups have expressed their support for Xilinx in the latest phase of its battle with the Internal Revenue Service. August 25, 2009

Hong Kong Court of Appeal clarifies situation for manufacturers

An important concession helpful to manufacturers using mainland China contract processors has been denied. August 19, 2009

TPDoctor: Modifications to documentation during the downturn

What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn? August 17, 2009


Estonia transfer pricing documentation checklist

Marko Saag of Glimstedt Straus & Partners Law Firm explains the transfer pricing documentation obligations in Estonia. March 09, 2010

Germany transfer pricing documentation checklist

Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime. March 08, 2010

Belgium transfer pricing documentation guide

Dirk Van Stappen of the KPMG in Belgium, provides a definitive guide to transfer pricing documentation policy. March 01, 2010

Japan transfer pricing documentation guide

Ken Okawara, Yukiko Komori, Satoko Kawamura, and Koji Oshima of Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) review the Japanese documentation situation. March 01, 2010

Malta transfer pricing documentation guide

Mirko Rapa and Berta Pisani Bencini of PricewaterhouseCoopers in Malta describe the country's documentation requirements March 01, 2010

Romania transfer pricing documentation guide

Ionut Simion and Blanca Kovari, of PwC in Bucharest, explain the Romanian tax authorities’ attitude towards transfer pricing documentation. March 01, 2010

Hungary transfer pricing documentation guide

Denes Szabo, tax partner and Hedvig Solyomvari, senior manager at Ernst &Young Budapest outline the transfer pricing documentation framework in Hungary. February 25, 2010

Ukraine transfer pricing documentation guide

Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine February 25, 2010

Singapore transfer pricing documentation guide

Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore. February 22, 2010

Argentina transfer pricing documentation guide

Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers February 11, 2009

China transfer pricing documentation guide

Steven Tseng and Chi Cheng, KPMG China January 21, 2009

Turkey Transfer Pricing Documentation Guide

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

Ecuador transfer pricing documentation guide

Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador August 21, 2008

Ukraine transfer pricing documentation guide

Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine June 23, 2008

Finland transfer pricing documentation guide

Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year April 24, 2008

Malta transfer pricing documentation guide

Mirko Rapa, of PricewaterhouseCoopers in Valetta, describes the regime for transfer pricing documentation in Malta April 15, 2008


Double tax treaties and transfer pricing in Poland

Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008

Double tax treaties and transfer pricing in Ecuador

Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping June 05, 2008

Double tax treaties and transfer pricing in Brazil

Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil June 04, 2008

Double tax treaties and transfer pricing in Peru

In the second in our series on double tax treaties, Gustavo López-Ameri of Deloitte & Touche in Lima reports on Peru's transfer pricing policy May 30, 2008

Double tax treaties and transfer pricing in India

KR Girish and Rohit Jain, of TP Week correspondent KPMG in India look at the impact of double tax treaties and transfer pricing May 28, 2008


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

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