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Hungary gets tough on transfer pricing

Hungary’s tax authorities have told taxpayers to comply with the country’s transfer pricing regime or risk facing large penalties November 19, 2008

Advisers criticise profit margin in resale price less profit method

Brazilian transfer pricing rules adopt fixed profit margins in methods applicable to import transactions. Fabia Moreira Azevedo of Machado Associados explains why many are critical of the percentage profits margins allowed under the rules November 18, 2008

Business restructuring is under the transfer pricing spotlight

Batanayi Katongera of Thomson Reuters warns corporations everywhere that business restructurings are under more scrutiny than ever before in light of the OECD discussion draft on the topic. November 18, 2008

Obama will change US transfer pricing

Advisers expect President-elect Obama's administration to put changes to transfer pricing rules high on its list of priorities when he takes office November 11, 2008

Incoming government puts off transfer pricing changes in New Zealand

New Zealand’s new government sees transfer pricing as a critical piece in the country’s international tax regime, but is unlikely to tighten the current rules amid a struggling economy, a leading professional says November 11, 2008

Israel clarifies approach to APAs

The Israeli Tax Authority (ITA) recently released the Income Tax Circular No. 3/2008 concerning transfer pricing November 05, 2008

Ceteris hires three and expands practice into Boston

Ceteris, a global economic consulting firm that provides transfer pricing, intellectual property and valuation services has expanded into the Boston area by hiring Jill Weise and Mark Bronson as managing directors, and Kate Sullivan as a director November 04, 2008

Industry body demands changes in India

Indian employers have called on the government to clarify transfer pricing rules and introduce an advance pricing agreement programme to encourage investment November 03, 2008

Russia must strengthen transfer pricing rules

Russia’s weak transfer pricing regime is hindering the countries development and making the country less attractive to foreign investment, says a leading professional firm November 03, 2008

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South-East Asia looks to tighten transfer pricing rules

Countries in South-East Asia are introducing or reforming their transfer pricing rules to increase revenues and attract foreign investment November 19, 2008

Indian authorities scrutinise cross-border restructuring

Atul Jain and Manisha Gupta of KPMG examine how the Indian tax authorities will approach modern business restructuring November 18, 2008

Marketing intangible assets can lead to exit taxes

In France, the concept of marketing intangible assets has led the tax authorities to imposing taxes on companies. Jean-Luc Trucchi explains what is happening. November 18, 2008

Thai court changes rule on share values

Transfer pricing advisers in Thailand are warning companies using a specific holding company investment structure that traditional treatment of their tax liability is changing November 12, 2008

Global economic crisis will effect transfer pricing in Uganda

As world markets plunge, even one of the world’s poorest nations is beginning to worry about the implications for them, and is turning to transfer pricing revenues as a means of survival November 11, 2008

India should introduce APAs and change data rules

Rahul Mitra of PricewaterhouseCoopers outlines the flaws in the Indian transfer pricing regime and explains why changes need to be made to support multinational companies operating in the country November 10, 2008

IRS plans action against transfer pricing breaches

The Internal Revenue Service wants to tighten transfer pricing rules to stop multinational companies with US operations using them illegally to cut their tax bills November 04, 2008

Kazakhstan to relieve transfer pricing burden on mining industry

Relaxing transfer pricing regulations is one method under consideration to assist Kazakh miners in trouble November 03, 2008


Court decisions throw up different opinions on use of quotes

Peter Andersen of Transfer Pricing Associates highlights the contrast in the results for two taxpayers from Danish litigation over the use of price quotes in transfer pricing September 02, 2008

Taxpayer wins ruling on dependent agents in India

The Bombay High Court has ruled that payment of arm’s length remuneration to a Dependent Agent Permanent Establishment (DAPE) in India extinguishes the tax liability of the foreign enterprise August 28, 2008

Tax authorities tighten transfer pricing rules

Taxpayers should take a more systematic approach to setting and documenting inter-company transactions as tax authorities worldwide seek to apply transfer pricing regulations more stringently, a new study says. August 20, 2008

UK unveils tax treaty programme

Key jurisdictions such as Belgium, China, Luxembourg and the US appear in the UK's tax treaty work plan over the next eight months August 20, 2008

Think-tank wants pricing transparency from oil companies

The IBON Foundation has hit out at oil companies’ reluctance to disclose how they determine what they charge for their products in the wake of windfall profits in the industry August 19, 2008

Court closes door on Symantec litigation

The US tax court has ruled in a landmark decision that details of a significant transfer pricing court case will not be made public. August 13, 2008

Transfer pricing helps companies in the US avoid tax

US corporations are using transfer pricing regulations to move profits out of the country to avoid paying federal income tax, said a report from the US Government Accountability Office (GAO). August 13, 2008


NERA Economic Consulting expands presence in China

NERA Economic Consulting opens Beijing office October 14, 2008

PricewaterhouseCoopers hires tax litigation expert

Ebrahim Ali, has joined PricewaterhouseCoopers Legal's tax litigation team October 14, 2008

KPMG adds to transfer pricing practice in China

KPMG’s global transfer pricing services group in China is expanding with a series of new hires which will take its total number of full time professionals to more than 100 October 08, 2008

Foley takes on new leadership role

KPMG has made two transfer pricing appointments in the Americas region and the US September 30, 2008

Gardere hires economist

A former Treasury and IRS official is joining US law firm Gardere Wynne Sewell as its chief economist September 25, 2008

TPA opens six new offices

Transfer Pricing Associates (TPA) Global has opened six new offices in Argentina, Brazil, Mexico, Switzerland and the US. September 19, 2008

PricewaterhouseCoopers adds two partners

Winnie Di and Cecilia Lee have become partners of PricewaterhouseCoopers's transfer pricing practice in Asia August 28, 2008

Granfield comes back to Ernst & Young

Michael Granfield is to rejoin Ernst & Young in its national transfer pricing practice in the US August 21, 2008

KMPG India appoints new head of tax

Uday Ved has been appointed head of tax at KPMG India. Ved joined the firm in 2006 from RSM & Co where he was a partner and head of tax. August 20, 2008


What Poland permits when calculating income

Jaroslaw Bieronski and Bartlomiej Bialy of Soltysinski Kawecki & Szlezak highlight the transfer pricing methods allowed in Poland July 14, 2008

Ukraine transfer pricing documentation guide

Vladimir Didenko of Magisters law firm provides practical comments on documentation requirements in Ukraine June 23, 2008

Finding a safe harbour in Brazil

TP Week correspondent Machado Associados reports on safe harbour rules in the Brazilian transfer pricing regime June 19, 2008

HMRC makes risk assessment key factor in enquiries

New guidance establishes rights and responsibilities of taxpayers June 19, 2008

Peru’s tax authority sets transfer pricing filing deadline

SUNAT issues guidance on filing dates for 2007 tax returns June 19, 2008


How the UK’s new approach to transfer pricing will work

Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process September 02, 2008

How you can protect IP and optimise your tax position in China

Glenn DeSouza, managing director, TP Management Consulting, Shanghai, and Benjamin Cheong, intellectual property group, Baker & McKenzie, Hong Kong believe you have to consider the tax implications when seeking to protect your intellectual property in China August 13, 2008

Arbitration Commission cases soar

A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP Week.com lists more than 350 cases. August 07, 2008

Australia’s AAT hands down final decision in Roche ruling

Stuart Edwards of PricewaterhouseCoopers, Australia, believes courts will favour traditional transactional transfer pricing methods rather than bottom line profits methods in the wake of the landmark Roche decision. July 30, 2008

AAR rules that referral fees paid to non-resident are not taxable in India

KR Girish and Himanshu Patel, of TP Week.com correspondent KPMG in India, believe the Authority for Advance Rulings was correct to use the narrow definition of fee for technical services under the double tax treaty with Singapore to decide the Cushman & Wakefield case in favour of the taxpayer July 24, 2008


New Zealand transfer pricing documentation guide

Leslie Prescott-Haar, of Ernst & Young, outlines the approach to transfer pricing documentation requirements in New Zealand February 19, 2008

Azerbaijan transfer pricing documentation guide

Mushfig Aliyev, of PricewaterhouseCoopers in Baku, describes the transfer pricing documentation environment in Azerbaijan March 13, 2008

Thailand transfer pricing documentation guide

Stuart Simons and Sangravee Thaidamri of Deloitte's transfer pricing team in Bangkok report on the transfer pricing documentation rules in Thailand March 11, 2008

Malta transfer pricing documentation guide

Mirko Rapa, of PricewaterhouseCoopers in Valetta, describes the regime for transfer pricing documentation in Malta April 15, 2008

Netherlands transfer pricing documentation guide

Monique van Herksen, a principal in Baker & McKenzie in Amsterdam, outlines the Dutch approach to transfer pricing documentation March 10, 2008


Double tax treaties and transfer pricing in Poland

Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008

Double tax treaties and transfer pricing in Ecuador

Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping June 05, 2008

Double tax treaties and transfer pricing in Brazil

Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil June 04, 2008

Double tax treaties and transfer pricing in Peru

In the second in our series on double tax treaties, Gustavo López-Ameri of Deloitte & Touche in Lima reports on Peru's transfer pricing policy May 30, 2008

Double tax treaties and transfer pricing in India

KR Girish and Rohit Jain, of TP Week correspondent KPMG in India look at the impact of double tax treaties and transfer pricing May 28, 2008


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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