The Internal Revenue Service (IRS) is inviting public comment on the development of bilateral safe harbours with US treaty partners, giving taxpayers and foreign competent authorities the opportunity to influence a safe harbour programme applicable to a large number of cross border transactions. But taxpayers and advisers have said there could still be disadvantages for multinationals.
March 27, 2013
The IRS has released statistics on transfer pricing cases for the calendar year 2012 – the first since the formation of the joint advance pricing and mutual agreement (APMA) programme. The figures signal growing taxpayer confidence in the restructured programme.
March 26, 2013
HM Revenue & Customs released its guidance on the new patent box regime in its Corporate Intangibles R&D Manuals (CIRD) and a series of road-shows.
March 04, 2013
The Danish tax authority, SKAT, has published its transfer pricing statistics, which show an increase in revenue from transfer pricing assessments, particularly through intellectual property (IP) transactions.
February 07, 2013
April 05, 2013
April 03, 2013
March 26, 2013
March 07, 2013
February 26, 2013
February 26, 2013
February 21, 2013
The founder of KPMG’s US transfer pricing controversy practice has formed his own transfer pricing law practice.
February 18, 2013
The Indian Central Board of Direct Taxes (CBDT) has issued guidelines to clarify the transfer pricing treatment of contract R&D centres. However advisers say the advice given is too vague and unlikely to reduce R&D disputes in India.
April 04, 2013
Canada’s 2013 budget included significant changes to cross-border taxation, including the broadening of the country’s thin capitalisation rules.
March 26, 2013
The first deadline for taxpayers in Russia to submit details of related-party transactions for 2012 may be delayed until the end of the year because of taxpayers’ concerns over the complexity of the notification requirements.
March 19, 2013
The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. The measure may force taxpayers to reassess the pricing of hybrid instruments.
March 07, 2013
The Korean government has issued guidance on the calculation of the arm’s-length price of guarantee fees for intercompany-guarantee transactions in response to a growing number of disputes involving companies receiving guarantee fees from their foreign subsidiaries.
March 05, 2013
P Chidambaram, the Indian Finance Minister, said in his budget speech today that rules on safe harbours will be issued.
February 28, 2013
New limits will be placed on the deductibility of interest on related party debt under the South African budget 2013, announced yesterday. However taxpayers are yet to receive clarification on the application of the arms-length test for inbound financial assistance.
February 28, 2013
Taxpayers need cost-sharing provisions to be written into Russian tax legislation to combat an increased risk of dispute over the allocation of shared service costs.
February 19, 2013
The OECD has identified transfer pricing as one of the challenges for policy makers and taxpayers as they attempt to reform how international tax rules work.
February 14, 2013
Robin Beran, chief tax officer and director for global tax and trade at Caterpillar, the machinery manufacturer, told delegates at the Tax Council Policy Institute conference on intangibles in Washington today that policy discussions about how to tax intangible assets are giving him “night terrors”.
February 13, 2013
Piergiorgio Valente, managing partner of Valente Associati GEB Partners, looks at the Italian case law surrounding the arm’s-length value of royalties.
March 20, 2013
Effective tax rate (ETR) planning is critical for all multinational enterprises. From a business flow standpoint, supply chain efficiency is critical.
October 30, 2012
Intangible assets are crucial sources of value and are of increasing strategic importance to companies.
October 16, 2012
Poland’s Supreme Court recently questioned the economic rationale behind the acquisition of procurement services from a related entity. Aneta Blazejewska–Gaczynska of Ernst & Young explains why this decision should force multinationals to examine their supply chain structures.
September 13, 2012
Differences between the tested transaction and the comparable transaction, when applying the transactional net margin method, should be adjusted where such differences materially affect the net profit margin, in accordance with rule 10B(e)(iii) of the Income Tax Rules.
September 07, 2012
Complex transfer pricing challenges are arising from the increasing number of joint ventures, particularly in the US, between multinational oil and shale gas exploration companies.
July 19, 2012
Location saving is a hot issue. Yin Chao, who specialises in transfer pricing at Siemens in China, and Yin Shuping, who is an associate professor at Guangdong Polytechnique Normal University, explain the transfer pricing aspects of location saving on contract R&D from China’s perspective.
July 12, 2012
A case concerning cost contribution agreements in a foreign company provides insight into how they should be structured for Indian taxation purposes.
June 01, 2012
By Barbara Dooley and Gavan Ryle of PwC, Dublin.
June 23, 2011
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
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador
March 23, 2011
Hans-Martin Jørgensen and Michael Vorndran of Deloitte
August 09, 2012
By Andrea Lahodny and Gabriele Holzinger of Deloitte
August 08, 2012
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
By Stefanos Mitsios of Ernst & Young
August 08, 2012
By Permana Adi Saputra of PB Taxand
August 08, 2012
By Bernice Tan of Taxand Malaysia
August 08, 2012
Tim Holmes and Thomas Bjerre of Ernst & Young Copenhagen outline the approach to the transfer pricing documentation requirements in Denmark.
August 03, 2012
Anthony Mahon and Andy El Zayaty of Deloitte provide a guide to the transfer pricing requirements in Egypt.
December 15, 2010
By Kathrine Kimball and Minjung Kim of Charles River Associates
July 26, 2012
By Graham Head (Senior Manager) and Liz Hughes (Transfer Pricing Director), Grant Thornton UK
July 24, 2012
By Taehyung Kim of Deloitte
July 23, 2012
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
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