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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
Komatsu, a Japanese construction equipment manufacturer, announced today that it is being investigated by the Japanese tax authorities over transfer pricing concerns.
March 11, 2010
China has released a circular that drastically changes the tax rules for foreign companies deriving income through establishments in China.
March 10, 2010
Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo discuss why Japan continues one of the most challenging jurisdictions for tax and transfer pricing in the world.
March 09, 2010
Purvez Captain and Steven Wrappe of Ernst & Young discuss the advantages and problems that can be found in adding to in-house professionals’ responsibilities.
March 08, 2010
The Brazilian Internal Revenue Service (Brazilian IRS) has published instructions providing the currency appreciation adjustment factor to be used in the calculation of transfer prices for the calendar year 2009.
March 03, 2010
With increased audit activity and recent tax litigation in Canada, determining the arm’s-length pricing of guarantees continues to be a difficult transfer pricing issue and risk for multinationals. Gordon Hands of CUFTanalytics discusses the issues raised in the GE Capital Canada’s guarantee fee transaction litigation.
March 01, 2010
Three new dispute resolution panels have been set up in Mumbai, New Delhi and Hyderabad to ease the burden of dealing with taxpayers’ applications for resolutions.
February 26, 2010
Amr El Monayer, assistant to the deputy minister of the Egyptian Ministry of Finance explains what the new guidelines will cover, and when they will be released.
February 25, 2010
India’s finance minister has told a conference of tax officials and taxpayers that transfer pricing must play a “special role” if India is to establish itself as a leading global economy.
February 22, 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
A Japanese multinational announced today that the Japanese and Singapore tax authorities had negotiated a bilateral advance pricing arrangement relating to the company’s Singapore operations.
March 10, 2010
An Indian authority has ruled that the assignment of rights and obligations is not taxable in India in the absence of a permanent establishment (PE).
March 05, 2010
TPWeek is adding to the library of documentation guides on TPWeek. This week, Belgium, Japan, Malta and Romania are new.
March 03, 2010
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
Advisers from Machado Associados summarise the new Brazilian transfer pricing rules and tax deductibility requirements.
February 25, 2010
The Mumbai Income Tax Appellate Tribunal has ruled that when determining the arm’s-length price of an international transaction, transfer pricing officers (TPO) must apply transfer pricing methods in accordance with the manner in which they are prescribed in the country’s transfer pricing rules.
February 25, 2010
Hasnain Shroff, A Pradeep and Vinita Chakrabarti highlight the key transfer pricing aspects that need attention in the forthcoming Union Budget 2010.
February 24, 2010
An eagerly awaited UK transfer pricing case will not now go to court.
February 24, 2010
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
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
China’s State Administration of Taxation (SAT) has issued a circular that identifies transfer pricing audit targets and specifically provides directives relating to special inspections of non-resident enterprises
September 09, 2009
India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules
September 08, 2009
The Venezuelan tax authorities have stepped up their attempts to generate extra tax revenue by targeting the transfer pricing methodologies of large automotive and pharmaceutical companies
September 02, 2009
Changes to India’s transfer pricing rules crucial for taxpayers.
September 01, 2009
In the current environment, multinational companies and their tax and transfer pricing advisers face unprecedented challenges, Clarke Norton, principal economist at DLA Piper in New York, identifies some transfer pricing opportunities.
August 19, 2009
The Ballentine Barbera Group, a Charles River Associates company that specialises in transfer pricing, has added three new consultants
February 18, 2010
Ceteris, a global economic consulting firm, has hired a partner of Ernst & Young to set up its transfer pricing practice in New Zealand.
February 02, 2010
Salim Rahim is now a partner in the Washington, DC office of Baker & McKenzie.
January 14, 2010
John Woodruff joins Gardere Wynne Sewell as a partner in the tax practice group in the Houston office.
January 06, 2010
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
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
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
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
India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules
September 08, 2009
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
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
What does the introduction of advance pricing arrangements mean for taxpayers in India?
September 01, 2009
In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing.
September 01, 2009
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
An important concession helpful to manufacturers using mainland China contract processors has been denied.
August 19, 2009
What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn?
August 17, 2009
Marko Saag of Glimstedt Straus & Partners Law Firm explains the transfer pricing documentation obligations in Estonia.
March 09, 2010
Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime.
March 08, 2010
Dirk Van Stappen of the KPMG in Belgium, provides a definitive guide to transfer pricing documentation policy.
March 01, 2010
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
Mirko Rapa and Berta Pisani Bencini of PricewaterhouseCoopers in Malta describe the country's documentation requirements
March 01, 2010
Ionut Simion and Blanca Kovari, of PwC in Bucharest, explain the Romanian tax authorities’ attitude towards transfer pricing documentation.
March 01, 2010
Denes Szabo, tax partner and Hedvig Solyomvari, senior manager at Ernst &Young Budapest outline the transfer pricing documentation framework in Hungary.
February 25, 2010
Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine
February 25, 2010
Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore.
February 22, 2010
Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers
February 11, 2009
Steven Tseng and Chi Cheng, KPMG China
January 21, 2009
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
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador
August 21, 2008
Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine
June 23, 2008
Outi Ukkola, of Deloitte & Touche Oy in Helsinki, describes the impact of new regulations which came into force last year
April 24, 2008
Mirko Rapa, of PricewaterhouseCoopers in Valetta, describes the regime for transfer pricing documentation in Malta
April 15, 2008
Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing
June 03, 2008
Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping
June 05, 2008
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
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
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
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
Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta
April 15, 2008
Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process
April 07, 2008
Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit
April 06, 2008
Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland
March 14, 2008