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

South Africa

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Amendments to TP rules in Serbia

In January 2014 the Ministry of Finance adopted amendments to the Serbian transfer pricing (TP) rulebook to ease certain TP requirements and resolve ambiguities and technical errors. April 14, 2014

US Multistate Tax Commission discusses launch of interstate TP audit programme

The US Multistate Tax Commission (MTC) has announced it aims to launch an interstate transfer pricing (TP) audit programme in July 2015. The move was brought on by Michael Bryan, director of the New Jersey Division of Taxation, challenging the commission to create a dedicated TP audit programme or risk a coalition of states creating their own. April 11, 2014

Defeat for UK government as European Court of Justice rules in favour of Hutchison Whampoa

Hutchison Whampoa recently won a bid for tax relief on losses by its UK mobile phone unit, Three, after the European Court of Justice (ECJ) found that Britain had violated EU anti-discrimination rules by blocking the transfer of the losses to group companies. The ruling has called into question the government’s ability to tax international groups under the control of third country parent companies. April 11, 2014

Research process has started for World Transfer Pricing directory 2015

The research has started for World Transfer Pricing 2015 and World Tax 2015, International Tax Review's directories of the leading tax and transfer pricing firms around the world. April 10, 2014

What the new IRS transfer pricing audit roadmap means for multinationals

The Internal Revenue Service (IRS) released its Transfer Pricing Audit Roadmap, in February, which is a 26 page document advertised as a “practical, user-friendly toolkit” for IRS transfer pricing specialists as well as other members of IRS Examination. April 09, 2014

Brazilian authorities change stance on withholding tax

The Brazilian tax authorities have adapted their stance on withholding tax (WHT) for technical services (without transfer of technology) for beneficiaries domiciled in countries that have a double tax agreement with Brazil. April 08, 2014

How OECD’s country-by-country proposals will impact India

The OECD’s country-by-country reporting (CBCR) discussion draft elaborates on its White Paper on Transfer Pricing Documentation, which was released on July 30 2013. April 07, 2014

UK backing of OECD’s BEPS project hints at weakening stance on interest deductions

The Treasury recently announced its support for a planned revamp of global tax rules which it warned would not always result in increased UK revenues or taxing rights. This has led many in the tax industry to worry about the pressure the OECD is placing on the UK to tighten its tax regime in ways that could undermine foreign investment in the country. April 04, 2014

US APMA stats for 2013 show promise but proposals have negative undertones

New proposals for APA and MAP applications, released during the last quarter of 2013, reflect changes in the advance pricing and mutual agreement programme’s (APMA) structure. The proposals emphasise a desire to resolve as many tax issues as possible in one procedural format. April 03, 2014

Joe Andrus's replacement as head of transfer pricing at OECD named

Joe Andrus, head of the transfer pricing division of the OECD, announced he would be leaving his post last year. His replacement has now been named. April 03, 2014

BEPS and its interraction between TP and indirect tax

The potential impact of the OECD’s BEPS project on indirect tax is a topic that has been overshadowed, with discussions focusing on intangibles and country-by-country Reporting (CBCR); however, it remains an important issue due to its strong links with transfer pricing (TP). April 02, 2014

Why tax market doubts country-by-country reporting

The OECD issued a revised draft of chapter V of the OECD guidelines on documentation in January, which placed emphasis on transfer pricing enquiry and risk assessment. Guidance on country-by-country reporting (CBCR) was one of the vital additions aimed at helping tax authorities with risk assessment. However, reactions have shown that, in its current state, CBCR may not be feasible. April 01, 2014

OECD announces changes to CBCR guidelines

At a recent conference in Paris, the OECD’s Joe Andrus, director of transfer pricing, discussed the results of Working Party 6 deliberations and announced the alterations that will be made to country-by-country reporting (CbCR) guidelines as a result of feedback from the tax industry. April 01, 2014

Experience of the EU coordinated documentation approach

The draft revised Chapter V of the OECD Guidelines, issued in January 2014, included a standardised two-tiered approach to transfer pricing documentation: a master file and a local file. Grant Thornton International member firms have looked at the experience of the existing coordinated approach in Europe. March 31, 2014

OECD digital economy discussion draft

The OECD published a discussion draft on the “Tax Challenges of the Digital Economy” this week, relating to Action 1 (address the tax challenges of the digital economy) of the action plan (AP) on base erosion and profit shifting (BEPS). March 27, 2014

APA trends in emerging markets

As business operations in emerging markets increase, more countries are implementing and developing advance pricing agreement (APA) regimes. China, India and Turkey represent three different approaches but indicate that APAs are an increasingly popular option for taxpayers in certain situations. March 27, 2014

UK intangibles guide

Danny Beeton and Murray Clayson, of Freshfields Bruckhaus Deringer, provide an overview of UK intangible property transfer pricing. March 25, 2014

Indian Special Bench questions choice of comparables in Maersk’s TP report

An Indian Special Bench ruling has emphasised the importance of functional comparability in transfer pricing (TP) reports and concluded that high margin comparables cannot be excluded. March 24, 2014

New PE ruling in Denmark reawakens concerns for foreign investors

The Danish National Tax Board recently issued a ruling which changed a limited partnership to the status of permanent establishment (PE), suggesting a move towards broader categorisation of what constitutes a PE. March 20, 2014

European law used in Turkish transfer pricing case

Turkey recently implemented European Court of Human Rights (ECHR) law in a transfer pricing case, signalling a pioneering move towards developments in taxpayers’ rights. March 19, 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

Why French taxpayers must start litigation to benefit from deferral of payment

French taxpayers must pay any additional tax assessed by the authorities in advance of a mutual agreement procedure, according to the country’s 2014 Finance Act (No 2013-1278). March 18, 2014

OECD paper on transfer pricing comparability data for developing countries could be a stretch too far

The OECD, last week, produced a paper on “Transfer Pricing Comparability Data and Developing Countries” in response to concerns about the poor quality and lack of availability of financial comparables data that many developing countries have access to. March 17, 2014

What the US bilateral safe harbour should look like

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

IRS stats signal growing faith in APMA programme

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

How to calculate the UK patent box

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

SKAT stats show Denmark’s persistence in assessing IP transactions

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

Indian guidance on R&D centres fails to reduce taxpayer confusion

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 broadens thin capitalisation rules in 2013 budget

Canada’s 2013 budget included significant changes to cross-border taxation, including the broadening of the country’s thin capitalisation rules. March 26, 2013

Russian transfer pricing deadline may be delayed because of burdensome notification

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

Germany proposes to limit participation exemptions for hybrid instruments

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

Korea clarifies arm’s-length calculation of intercompany guarantee transactions

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

Indian safe harbour rules will be issued says Chidambaram

P Chidambaram, the Indian Finance Minister, said in his budget speech today that rules on safe harbours will be issued. February 28, 2013

South Africa limits interest deductibility on related party debt

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 law in Russia to combat shared service disputes

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

OECD unveils G20 report on base erosion and profit shifting

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

Why intangible policy discussions are giving Caterpillar’s head of tax “night terrors”

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

Arm's-length value of royalties: Italian case law

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

Japan-China supply chain efficiency valuation and transfer pricing

Effective tax rate (ETR) planning is critical for all multinational enterprises. From a business flow standpoint, supply chain efficiency is critical. October 30, 2012

IP Structuring: Tax planning ideas for intangible assets

Intangible assets are crucial sources of value and are of increasing strategic importance to companies. October 16, 2012

Polish court challenges procurement transaction

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

Selecting the interest rate for working capital adjustments

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

Where transfer pricing is critical in US oil and gas joint ventures

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

Siemens’ tips on location saving in Chinese contract R&D arrangements

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

What the Indian Authority on Advance Rulings thinks of cost contribution arrangements

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

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


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