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

South Africa

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Indian finance minister keeps transfer pricing at “arm’s-length” in 2015-16 budget speech

Taxpayers think the 2015 Indian budget, announced on Saturday, did not focus strongly enough on transfer pricing and have described it as “disappointing”. March 04, 2015

Microsoft IRS transfer pricing case dismissed

Microsoft and the Internal Revenue Service (IRS) have agreed to end their battle over documents used in transfer pricing audits of the tech company. March 04, 2015

Indonesia wages war on corporate tax avoidance through transfer pricing

The director-general of taxes in Indonesia has confirmed government plans to clampdown on corporate tax avoidance facilitated by transfer pricing. March 03, 2015

Timing of Canada Revenue Agency’s TPM-16 on multiple year data “odd” in light of pending OECD recommendations

The Canada Revenue Agency (CRA) has released transfer pricing memorandum 16 (TPM-16), which formalises guidance on multiple year data. While the guidance is far from ground-breaking, the timing of its release appears odd because the OECD’s final recommendations have yet to be published March 03, 2015

How HMRC is tackling tax arrangements similar to Starbucks’

The Public Accounts Committee (PAC) met last month to ask HM Revenue & Customs (HMRC) about its efforts to curb tax avoidance, including how HMRC has developed its transfer pricing approach to counteract tax arrangements such as those by Google, Amazon and Starbucks. March 03, 2015

Canada Revenue Agency ignores the OECD’s simplified proposals for intra-group services in TPM-15

The Canada Revenue Agency (CRA) has released transfer pricing memorandum TPM-15 on intra-group services which overlooks the OECD’s proposals for a more simplified approach. February 26, 2015

Transfer pricing steals the show in South African finance minister’s 2015-2016 budget speech

South African finance minister, Nhlanhla Nene, has stressed the importance of regulating transfer pricing to tackle profit shifting in the country in his 2015/2016 budget speech. February 26, 2015

US Multistate Tax Commission proposes TP regime to tackle interstate income shifting

The US Multistate Tax Commission’s (MTC) Arm’s Length Adjustment Services (ALAS) programme is a response to interstate income shifting. The MTC hopes to provide state governments with a comprehensive programme to increase state transfer pricing revenues. February 25, 2015

IRS threatens to penalise Caterpillar over profits earned from Swiss subsidiary

After investigating Caterpillar’s US tax returns, the Internal Revenue Service (IRS) is threatening to tax profits the company earned from its Swiss based subsidiary (Caterpillar SARL). Caterpillar claims nothing untoward took place and plans to challenge the IRS through the appeals process. February 24, 2015

Acting ahead of final OECD recommendations could put BEPS project in jeopardy

With the deadline for the base erosion and profit shifting (BEPS) project still some time away, governments are deliberating whether to take the issue into their own hands and act ahead of final OECD recommendations in December 2015. February 24, 2015

ICC attempts to close gap between TP and customs

The International Chamber of Commerce (ICC) has released a statement on the challenges of harmonising indirect tax and transfer pricing. February 19, 2015

Level of confidentiality in CbCR continues to be Achilles' heel of the OECD’s BEPS project

The OECD’s implementation guidance on country-by-country reporting (CbCR) has done little to placate the debate between multinationals and non-government organisations (NGOs) over the degree of confidentiality required in documentation. February 18, 2015

Indian budget 2015: What taxpayers want to hear on indirect share transfers

Taxpayers and their advisers want the Indian government to clarify a number of issues including indirect share transfers in their 2015 budget on February 28. February 17, 2015

ATO says ECAP programme is only in pilot stages and dismisses claims it would aid tax cheats

The Australian Taxation Office (ATO) has been accused of pushing for big corporations to conduct their own tax audits. Negative comments in the media and statements from alleged employees claim the ATO’s efforts to reduce costs will ultimately result in victory for tax cheats. February 13, 2015

Hasbro agrees to pay Mexican SAT $4.38 million over tax avoidance claims

A spokesperson for US toy company Hasbro announced the company had agreed to pay the Mexican tax authorities (SAT) $65 million ($US 4.38 million) to settle tax avoidance claims. Hasbro is unlikely to be the only multinational to pay up. February 11, 2015

Hong Kong shows eagerness to provide tax certainty with conclusion of first bilateral APA with Japan

Hong Kong’s Inland Revenue Department (IRD) has concluded its first bilateral advance pricing agreement (APA) with the Japanese tax authorities. The APA highlights the IRD’s willingness to cooperate with other countries to bring greater tax certainty to Hong Kong. February 10, 2015

PAC report makes an example of PwC and urges HMRC to take a more active role in challenging tax arrangements

The Public Accounts Committee (PAC) released a report on tax avoidance, focusing primarily on tax arrangements between pharmaceutical company Shire and PwC. PAC’s insistence on making an example of PwC throughout the report shows the government has no qualms about publicly naming and shaming advisers. February 06, 2015

New wave of transfer pricing audits in Belgium

This week, almost 200 taxpayers in Belgium received a detailed information request regarding their transfer prices. February 06, 2015

French oil company Total to close all tax haven subsidiaries in bid to promote transparency

French oil company Total has announced plans to close subsidiaries in tax havens in a bid to prove it is making conscious efforts to clean up its tax policy. However, it remains to be seen whether Total’s intentions are genuine or simply a publicity stunt. February 06, 2015

EC announces in-depth state aid investigation of Belgian excess profit ruling system

Yesterday the European Commission (EC) published a press release that it will further conduct an in-depth state aid investigation into the so-called Belgian excess profit rulings system. February 04, 2015

Amendments to TP rules and the proposed introduction of CbCR suggest greater alliance between Spain and OECD

The Spanish government recently changed its transfer pricing rules regarding documentation requirements and penalties. These amendments show Spain is aligning itself more closely to OECD guidelines. February 04, 2015

LG awaits Delhi High Court ruling on taxation of marketing intangibles

Indian tax authorities have said that businesses spending higher than average on advertising, marketing, and promotions (AMP) expenses are creating marketing intangibles for related foreign enterprises and are therefore liable for taxes on expenditures above average for comparable transactions. February 03, 2015

BEPS feedback highlights a lack of taxpayer confidence in the OECD's work on double taxation and dispute resolution

Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dispute resolution. February 02, 2015

New French TP provisions call for tightening up of documentation but should lower audit costs

France recently enacted transfer pricing provisions detailing penalties taxpayers can incur for noncompliance regarding documentation requirements. A regularisation procedure has also been formally implemented which should reduce the cost of transfer pricing audits. February 02, 2015

India’s CBDT asks ITAT and DRP to apply Vodafone ruling to similar transfer pricing cases

The Central Board of Direct Taxes (CBDT) has requested that Income Tax Appellate Tribunals (ITAT) and dispute resolution panels (DRP) apply the principle behind the Bombay High Court’s Vodafone ruling for similar transfer pricing cases. February 02, 2015

New APA regulation released in Indonesia

The release of the Indonesian Ministry of Finance’s regulation Number 7/PMK.03/2015 (PMK-07) on the implementation of advanced pricing agreements (APA) is welcome news for Indonesian taxpayers that currently have an APA in progress or are considering filing for one. February 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

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

Ireland transfer pricing documentation guide

By Barbara Dooley and Gavan Ryle of PwC, Dublin. June 23, 2011

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

Ecuador transfer pricing documentation guide

Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador March 23, 2011

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

Canada transfer pricing documentation guide

Todd Miller and Michael Friedman of McMillan in Toronto, Canada explain the documentation rules in Canada and how recent treaty developments and court decision will affect taxpayers. April 20, 2010

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

Egypt – Transfer Pricing Documentation Requirements

Anthony Mahon and Andy El Zayaty of Deloitte provide a guide to the transfer pricing requirements in Egypt. December 15, 2010

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