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Poll

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

Brazil
1%
Russia
20%
India
21%
China
20%
South Africa
38%


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Content

Majority of taxpayers are concerned IT systems are not up to scratch for BEPS

The majority of taxpayers, in a survey by TPWeek, have said they think the IT systems available on the market for corporate tax and transfer pricing are insufficient in helping companies to cooperate with documentation and the country-by-country reporting obligations of the upcoming BEPS guidance. July 01, 2015

Germany moves towards country-by-country legislation

The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country-by-country (CbC) reporting) of the OECD’s BEPS project into local legislation. July 01, 2015


Pfizer, Novartis and AstraZeneca among companies called to Australian senate inquiry

Nine multinational drug companies have come under scrutiny from the Australian authorities. The companies were called before a senate committee hearing today after data showed that, from their combined revenue of AUS$8.2 billion ($6.3 billion), they had paid AUS$85 million. July 01, 2015

WCO working with ICC to overcome TP and customs discrepancies

The World Customs Organization (WCO) has released a new guide on customs valuation and TP. The guide includes recommendations from the International Chamber of Commerce (ICC) to converge disparate TP and customs policies. June 30, 2015


Read the most popular articles so far this year on TPWeek

An exclusive interview with Andrew Hickman, head of TP at the OECD, along with insights from LEGO China, guides to engage the board in a company’s TP affairs and IP risks in asset management, are the most popular articles so far on TPWeek. June 29, 2015

A quarter of companies’ tax departments will not receive any extra resources to cope with BEPS changes

A TPWeek survey has revealed that country-by-country reporting (CbCR) is the biggest worry for multinationals before the final BEPS outcomes are revealed in October and that an alarming proportion of companies have not spoken to their board about BEPS. Of those who have, a large percentage will not be receiving any extra resources to cope. June 29, 2015


Importance of comparability factors in transfer pricing analyses

The Italian Supreme Court has ruled that transfer pricing adjustments applied by the tax authorities may be deemed legitimate even if they have been applied after a comparison between the transactions assessed and the ones carried out by and among third independent parties. June 29, 2015

Next round of TP inspections due for Czech Republic

The Czech Republic’s Specialized Tax Authority has announced, via its website, a new round of transfer pricing inspections. The inspections are due to begin this month. June 26, 2015


EC tax haven list attracts wide-spread criticism

The European Commission (EC) has released a list of the 30 worst-offending tax havens in an attempt to coordinate EU states’ approaches to blacklisting non-EU countries. June 26, 2015

Ecuador issues new transfer pricing requirements

The Ecuadorian Tax Authority (Servicio de Rentas Interno or SRI) issued new regulations last month, under Resolution No. NAC-DGERCGC15-00000455, introducing updated transfer pricing requirements for intercompany transactions. June 24, 2015


Brazil clarifies aspects of import export methods

The Brazilian Federal Revenue Secretariat has issued Normative Instruction (NI) 1,568/15, to clarify specific aspects of the PCI and the PECEX methods for imports and exports. June 24, 2015

Nigerian government ramps-up focus on multinational taxation

The Nigerian government has ratified the Convention on Mutual Administrative Assistance in Tax Matters, in an effort to better manage the tax affairs of multinational companies operating in Nigeria. June 23, 2015


Thailand deliberates transfer pricing law

Thailand’s Council of State is deliberating the country’s first law on transfer pricing. If passed the bill would allow Thailand Revenue Department (TRD) officials to enquire into profits from cross-border transactions of multinational companies. June 23, 2015

Industry tax and TP leaders to discuss BEPS integration of technology

Corporate heads of tax and TP will meet to discuss how best to approach the issue of integrating technology systems in light of pending BEPS guidance. June 17, 2015


AstraZeneca on hindsight in the valuation of intangibles

The OECD is considering the use of hindsight when tax authorities are assessing hard-to-value intangibles (HTVI). Ian Brimicombe, VP of corporate finance at AstraZeneca in the UK, discusses the impact on taxpayers. June 15, 2015

Are you getting the transfer pricing information you need?

Transfer pricing is not an exact science and practitioners need access to as much information as possible to ensure they are staying ahead of the curve. June 12, 2015


The OECD’s introduction of ex-post evidence could prove difficult in hindsight

The OECD, as part of action 8 of its BEPS plan, has released a discussion draft looking at the issue of hindsight and the arm’s-length pricing of hard-to-value intangible assets. June 11, 2015

New Zealand tightens tax enforcement for multinationals

The New Zealand Budget has reaffirmed the government’s key priority of collecting taxes by allocating an additional NZ$74 million ($51 million) over five years for Inland Revenue’s investigations. June 11, 2015


Pascal Saint-Amans discusses model legislation for CBCR implementation

The OECD has published a 42-page Country-by-Country Reporting Implementation Package this week, which consists of model legislation, a multilateral competent authority agreement on the exchange of country-by-country reports, two other competent authority agreements, one based on a double tax convention, the other based on a tax information exchange agreement (TIEA), and a confidentiality and data safeguards questionnaire. June 10, 2015

Argentine Supreme Court rules on transfer pricing of commodity exporters

The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, two months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). June 09, 2015


BEPS and what it means to the UK investment management industry (part 2)

The OECD base erosion and profit shifting BEPS project is expected to publish a large amount of material over the coming months, with the period September to December 2015 being particularly busy. June 08, 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


New transfer pricing partner at PwC Ireland

June 18, 2015

DLA Piper boosts TP practice from London office

June 17, 2015

Andersen Tax boosts TP department in US

June 10, 2015

Transfer pricing attorney joins Baker & McKenzie

Transfer pricing attorney, Barbara Mantegani, has joined Baker & McKenzie’s Washington DC tax practice as counsel. April 08, 2015

Schoeneborn joins EY from Merck

Dr. Frank Schoeneborn joins EY as a partner in EMEIA Tax Centre focusing on intercompany effectiveness and operational transfer pricing. March 27, 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