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

South Africa

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Microsoft among MNEs facing greater scrutiny in New Zealand

Microsoft’s New Zealand unit is one of several companies that will be subjected to a transfer pricing audit as the tax authority ramps up its scrutiny of the technology sector. January 19, 2017

Big mining companies in Africa must brace themselves for increased audits

African countries are targeting the mining sector with audits based on suspicions that commodities are not being sold at arm’s-length prices. January 17, 2017

Will the UK become a tax haven after Brexit?

A storm of controversy has been whipped up surrounding Chancellor Philip Hammond’s suggestion the UK might look to become a tax haven post-Brexit. How might this work in terms of TP policy and what does it mean for Europe? January 17, 2017

Greek new MAP meets international standards and new measures on M&As are introduced

Amendments to the Greek Procedural Tax Code and the Income Tax Code introduce a host of changes, including the introduction of the mutual agreement procedure (MAP) and measures on M&As. January 12, 2017

Indonesia adopts CbCR and new transfer pricing documentation requirements

B. Bawono Kristiaji, Romi Irawan and Yusuf Wangko Ngantung from DDTC report on CbCR and new transfer pricing documentation in Indonesia. January 12, 2017

Ukraine bucks the BEPS trend on TP rules

Ukraine’s new TP rules do not fully conform to international trends, but they will come as a relief to taxpayers. January 12, 2017

What is behind Snapchat’s savvy UK sales move?

Snap, the company behind the iconic messaging app Snapchat, is looking to the UK to book advertising sales for tax, and probably PR, purposes. January 12, 2017

Luxembourg levels the playing field for intra-group activities

Luxembourg’s new transfer pricing (TP) circular clarifies the transfer pricing matters arising in connection with intra-group financing activities for all entities in the country. January 10, 2017

Vorwerk Group hires new TP manager

Carsten Bonnerup has joined Germany-based corporate group Vorwerk Group as a senior transfer pricing (TP) manager. January 10, 2017

Garrigues Consultores Tributários joins Taxand

Garrigues Consultores Tributários has joined Taxand as the organisation’s member firm in Brazil. January 10, 2017

World Bank publishes TP handbook

The World Bank’s newly published handbook on transfer pricing (TP) aims to benefit policymakers, TP advisers and in-house practitioners in developing countries. January 05, 2017

Tax treaty trouble expected from OECD’s Multilateral Instrument

The OECD claims its Multilateral Instrument will help countries swiftly implement measures from the BEPS Project, but tax experts warn that challenges in deciphering double tax agreements will arise. January 03, 2017

Croatia's transfer pricing rules

Transactions involving a Croatian entity are subject to transfer pricing (TP) rules that are mainly in line with international standards, but taxpayers should be aware of the regulations. December 29, 2016

Poland’s TP rules on CbCR apply from 2017

Businesses need to be ready for new regulations on transfer pricing documentation that will apply in Poland from January 1 2017, which will also impose new requirements on taxpayers conducting related-party transactions. December 29, 2016

Long-term benefits of first India-US bilateral APA

India and the US agreed on the terms and conditions of the first bilateral advance pricing agreement (APA) between the two countries in October, but how will this impact companies in the future? December 21, 2016

Suitable TP documents could prevent penalties in Italy: But what is “suitable”?

Multinationals with activities in Italy can get rid of penalties for tax avoidance if they opt to supply the Italian revenue authorities with comprehensive transfer pricing (TP) documents supporting their group’s TP policies. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain how this works in practice. December 20, 2016

French court rules that public CbCR is unconstitutional

In a promising development for businesses, a French court has decided that public country-by-country reporting (CbCR) is unconstitutional. But how will this go along with the government’s enthusiasm for public CbCR within the EU? December 19, 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