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

South Africa

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Britain may have overstepped its powers by trying to impose CbCR anti-avoidance regulations

The UK may have acted beyond its powers in its push to implement BEPS by including a targeted anti-avoidance rule (TAAR) in country-by-country regulations, according to Britain’s Select Committee on Statutory Instruments. May 04, 2016

Australia Budget introduces Diverted Profits Tax

Multinationals are targeted in Australia’s 2016-2017 budget with Treasurer Scott Morrison aiming to collect an additional AUS $3.9 billion ($2.9 billion) in tax from MNEs by 2020. May 03, 2016

WCO transfer pricing tool to bring certainty in determining duty liabilities

The World Customs Organisation’s (WCO) Technical Committee on Customs Valuation has finalised a tool to improve how authorities manage the interaction of customs and transfer pricing. But the WCO admits it is an ongoing struggle and more work will be needed to improve the environment for business. May 03, 2016


The latest headline news from Transfer Pricing Week. News Briefs include: Turkey preparations for the electronic permanent establishment concept; Australia’s budget plan for diverted profits tax; WCO tool for customs and transfer pricing and BEPS on the agenda at this week’s ABA meeting. May 03, 2016

Australian budget preview: multinationals targeted?

The Australian budget for 2016-2017 is released on Tuesday. TP Week looks ahead to see which policies are likely to be unveiled to tame the fury over cross-border taxation. May 02, 2016

Russia issues draft law opening the door to BEPS

Russia’s Ministry of Finance has reportedly issued a draft law that would bring its transfer pricing documentation rules in line with the OECD’s base erosion and profit shifting (BEPS) proposals under Action 13. April 29, 2016

Ex-PwC employee tells court he had a 'duty' to act on sweetheart tax deals

Raphael Halet, a PwC employee on trial in the so-called ‘LuxLeaks’ tax scandal, said he decided to act after seeing a France 2 television report in 2012, a story it later transpired was based on the alleged leak of 30,000 tax documents by ex-PwC auditor Antoine Deltour. April 29, 2016

PwC names Kevin Ellis chairman and senior partner in UK, Middle East

Kevin Ellis, 52, currently managing partner, starts his four-year term July 1 when Ian Powell retires. Ellis has been a PwC partner for 20 years and has led in growth areas including cyber security, data and analytics. April 29, 2016

TP WEEK NEWS BRIEFS For April 28, 2016

The latest headline news from Transfer Pricing Week. News Briefs include: Latin America loses $100 million to transfer pricing; EC's Ireland-Apple investigation; ‘LuxLeaks’ whistleblower trial; Australia penalties for corporate tax avoidance; and OECD to address tax avoidance in Kyoto. April 28, 2016

OECD Brexit Report: UK exit from EU would cause 'major shock'

Britain's departure from Europe would be a ‘major negative shock’ to the UK economy, costing each household about £2,200 ($3,200) a month, and the economic fallout would be felt throughout Europe, the OECD said in a report released today, two months before the UK's 'Brexit' referendum. April 27, 2016

TP WEEK NEWS BRIEFS For April 27, 2016

The latest headline news from Transfer Pricing Week. TP News Briefs include: Brexit tax implications outlined at OECD conference in London; Australian fines for firms involved in tax evasion advice; and LuxLeaks trial day two. April 27, 2016

Europe divided over plan for MNEs to publish EU and offshore tax data

Finance ministers are split over EU draft rules requiring multinationals to publish country-by-country tax reports (CbCR), with some politicians urging caution and others warning that Europe is overreacting to the ‘Panama Papers’ uproar. April 26, 2016

Ex-PwC auditor Deltour and two others face prison as ‘LuxLeaks’ trial gets underway

Former PwC auditor Antoine Deltour stands trial in Luxembourg today on charges related to accessing a database of confidential corporate tax deals later published by a French journalist. The whistleblower is accused of theft and breach of professional secrecy, among other charges. April 26, 2016

TP WEEK NEWS BRIEFS For April 25, 2016

The latest headline news from Transfer Pricing Week. TP News Briefs include: the impact of US Treasury plans for earnings stripping on foreign MNEs; Australian deal to fast-track corporate tax cases, Czech Transfer Pricing Inspections; OECD to focus on BEPS; and US IRS meeting on new CbCR rules. April 25, 2016

US anti-inversion rules to have ‘enormous impact’ on foreign MNEs

The US Treasury’s proposed regulations on ‘earnings stripping’ will cause headaches for foreign multinationals, including increased administration, additional costs and limitations with debt leveraging, tax advisors warn. April 25, 2016

Apple co-founder Wozniak says companies should pay 50% tax

Steve Wozniak, co-founder of Apple along with Steve Jobs, said that all companies, including Apple, should pay the same rate of tax as he does personally. April 22, 2016

India FM: Vodafone appeal is unrelated to retrospective taxation

Finance Minister Arun Jaitley has defended India's decision to appeal a Bombay High Court ruling in the Rs 8,500 crore ($1.7 billion) Vodafone transfer pricing case, saying it is not related to a separate, retrospective tax issue. April 21, 2016

The Platform for Collaboration on Tax: The same old story?

The world's largest multilateral organisations laid out plans for a joint ‘platform’ to help developing countries fight tax evasion, the first steps toward creating international standards. Tax campaigners aren’t convinced that the announcement actually assists developing countries. April 21, 2016

IMF, UN, World Bank and OECD to help developing countries fight tax evasion

The world's largest multilateral organisations laid out plans yesterday for how their joint ‘platform’ will help developing countries fight tax evasion, in the first steps toward creating international standards. But are the concepts really new? April 20, 2016


The latest headline news from Transfer Pricing Week. TP News Briefs include: Bermuda signs a MCAA and adopts CbCR; Indian outlines draft rules for foreign tax credit; and PNG deflects allegations of tax evasion in the logging industry. April 20, 2016

Ex-US Treasury officials: America’s new ‘inversion’ regulations will push US companies overseas

Eighteen ex-Treasury officials are lobbying US President Barack Obama to reconsider new ‘inversion’ rules announced after Pfizer’s failed $160 billion merger with Ireland’s Allergan, saying the regulations will encourage US companies to move abroad and exacerbate the problem. April 19, 2016

India aims to resolve 100 transfer pricing cases by March 2017

India hopes to sign another 100 advance pricing agreements (APAs) with multinationals by the end of March 2017, an ambitious target and almost double the number of APAs signed in 2015-2016. April 19, 2016

Was the Pfizer-Allergan merger proposal really a windfall for Ireland?

When new rules proposed by the US Treasury stopped the $160 billion Pfizer-Allergan super-inversion in early April many Americans applauded. Some grumbled about unfair tax loopholes or blamed Ireland’s 12.5% corporate tax for luring away American companies who pay up to 35% tax back home. April 18, 2016

UK MP David Gauke: Companies do a ‘poor’ job explaining tax data

Companies are doing a poor job communicating their tax positions, David Gauke, the financial secretary to the UK Treasury, told the European Tax Policy Forum conference in London today. April 18, 2016


The latest headline news from Transfer Pricing Week. TP News Briefs include: American concerns about corporate ‘inversions’; ICC worries over EC’s tax haven plans; Jamaica's new Transfer Pricing legislation; and South Africa’s draft CbCR legislation. April 18, 2016

Panama to adopt Common Reporting Standard on AEOI

After years of wavering, Panama will finally adopt international tax reporting standards following the leak of 11.5 million financial documents and two weeks of intense scrutiny focused on the Central American tax haven. April 15, 2016

Research for World Tax and World Transfer Pricing 2017 has begun

Everything you need to know about submitting for International Tax Review's World Tax and World Transfer Pricing directories. April 14, 2016

Tax inspectors meet for urgent OECD 'Panama Papers’ talks in Paris

Hours after police raided the headquarters of Panama City law firm Mossack Fonseca, the OECD held a high-level meeting of international tax inspectors keen to use cross-border investigations to hunt down tax evaders. April 13, 2016

TP WEEK NEWS BRIEFS For April 13, 2016

The latest headline news from Transfer Pricing Week. TP News Briefs include: the Panama Papers' JITSICN special meeting in Paris, the EC's proposed legislation targeting MNEs with European and offshore subsidiaries, the release of South Africa's CbCR draft regulations and Jamaica's collaboration with the OECD on transfer pricing April 13, 2016

EXCLUSIVE: OECD’s Saint-Amans discusses EC push to force MNEs to publish CbCR data on their websites

The European Commission’s crackdown on EU and foreign multinationals includes a plan to force MNEs operating in Europe to publish detailed country-by-country tax reports on their company websites – including financial data from offshore subsidiaries. April 12, 2016

European Commission demands MNEs publish EU and offshore tax data

The European Commission is pushing EU and foreign multinationals to publish detailed country-by-country tax reports on their company websites – including financial data on their businesses in Europe and offshore. April 12, 2016

Patent box in Italy: Guidelines issued by the Italian revenue office

The 2015 Stability Law introduced in Italy a new patent box regime for incomes deriving from the use of specific categories of intangibles. The regime, applicable as of tax year 2015, may be adopted by entities earning corporate income. April 12, 2016

BEPS: The impact survey

While the wave of international taxation triggered by the OECD’s 15 BEPS recommendations is designed to bring consistent tax reform globally, it may also be creating a new set of problems. April 12, 2016

UK escalates plan to criminalise tax evasion advice

British Prime Minister David Cameron says he will fast-track plans to impose criminal penalties on companies whose staff enable tax evasion. April 11, 2016

Growing demand for US APAs

The IRS has released statistics on its advance pricing and mutual agreement (APMA) programme for 2015, which show a sharp increase in the number of US multinationals applying for advance pricing agreements (APAs) than in previous years. April 07, 2016

Canada budget reveals revenue agency holding back on BEPS

Canada’s 2016 Budget introduced a number of BEPS-inspired regulations, including country-by-country reporting (CbCR) and the updated definition of the arm’s-length principle. April 05, 2016

New penalties for Greek TP failures

The most important development that took place in the last months of 2015 with regard to Greece’s transfer pricing regime was the enactment of Law 4337/2015, which led to the rationalisation of the respective penalty system. March 31, 2016

Net Entertainment wins against Swedish tax authorities

The Swedish Administrative Court of Appeal has upheld gaming software supplier Net Entertainment’s appeal against the Swedish tax authority’s transfer pricing adjustment. March 31, 2016

Why investors are pushing for transparent tax planning

The transparency of multinationals’ tax practices is a growing concern for investors because reputational damage from transfer mispricing can negatively affect share prices. November 26, 2015

OECD statistics show MAP remains necessary but slow

The OECD has released statistics on MAP cases for its member states and related economies for 2014. December 01, 2015

Northern Ireland tax rate introduces TP challenge

Northern Ireland will reduce its corporate tax rate to 12.5% in 2018, bringing it in line with the Republic of Ireland tax rate but below the rest of the UK. December 03, 2015

Johann Muller: How a European CCCTB makes BEPS action points “irrelevant”

Johann Muller was the deputy head of tax for a major multinational and, following that, the chief consultant at the Danish competent authority. From both perspectives he sees the benefits and need for a common consolidated corporate tax base (CCCTB) in Europe. December 10, 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