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News and Analysis

  • Indonesia tax audit guideline for affiliated transactions

    December 01, 2013

    Over the past four years, the Indonesian Directorate General of Tax (DGT) has been placing great focus on the tax potential from related-party transactions within multinational groups of companies. The DGT has issued regulations on transfer pricing guidelines, developed its human resources, equipped itself with commercial database, and undertaken audits particularly when there are intercompany transactions. Sri Wahyuni of SF Consulting provides an overview of the changes and explains what taxpayers need to do to guard against audit.

  • Germany’s new rules on profit allocation to insurance PEs

    November 01, 2013

    Ulf Andresen and Jobst Wilmanns of PwC in Frankfurt, explain how Germany’s new profit allocation rules for insurance permanent establishments (PE) potentially discriminate against foreign insurers.

  • Industry insights for Asian taxpayers

    October 14, 2013

    Tax directors from some of the largest multinational companies, including Siemens, Caterpillar, Noble, GE, Citi and Standard Chartered, will share their transfer pricing insights and experiences in Singapore later this month.

  • Business conference with OECD on BEPS: Will Morris of BIAC reacts

    October 08, 2013

    The OECD met with BIAC (Business and Industry Advisory Committee) last Tuesday in Paris to discuss industry’s concerns over the base erosion and profit shifting (BEPS) project. Will Morris, chairman of BIAC’s tax and fiscal policy committee, tells ITR how the meeting went and what can be expected to happen next from an industry perspective.

  • TP arbitration for developing countries: Benefits and burdens

    October 01, 2013

    The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in a personal capacity about some of the issues that may shape transfer pricing arbitration clauses and how they operate in future for taxpayers and their advisers.

  • Foreign employee secondments and the PE issue

    October 01, 2013

    Companies often second their employees to other firms in their group abroad but this can create a permanent establishment (PE) risk; something that can take up an unreasonable amount of time for a tax director if not handled properly. Sophie Ashley speaks to taxpayers and their advisers about how best to manage the situation to avoid creating a PE.

  • Americas Awards 2013 shortlists for ceremony in two weeks

    September 13, 2013

    International Tax Review has added the final categories to the shortlists for the Americas Awards 2013, which recognise the most outstanding provision of tax services in North and South America between June 2012 and June 2013.

  • Leading industry professionals share their experience on difficult transfer pricing issues

    August 05, 2013

    Leading transfer pricing professionals from industry including Caterpillar, Nissan Europe, The Dow Chemical Company, Hewlett-Packard, Dell, Alstom, Lexmark International and Brown-Forman, along with officials from the OECD and the IMF, have agreed to share their industry experiences of some of the most difficult and contentious issues in transfer pricing.

  • What you have missed on ITR Premium

    January 14, 2013

    BAE Systems; Ireland US FATCA agreement; UK MP publishes FTSE100 transparency responses; Cyprus IP regime; Vietnam VAT exemptions; exits Jersey; Hong Kong Court of Appeal; Canada Revenue Agency transfer pricing policy

International Correspondents