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Transfer Pricing

  • World Tax 2015 and World Transfer Pricing 2015: Research open

    April 10, 2014

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

  • International updates - April 2014

    March 31, 2014

    The latest tax updates from around the world.

  • Teamwork central to Telefônica’s tax compliance in Brazil

    March 28, 2014

    Vasco Gruber Franco is head of tax for the Telefônica group in Brazil. He previously worked on the advisory side at Arthur Andersen, and has held other in-house roles at DuPont and Philip Morris. Here, he talks to Matthew Gilleard about heading up a tax department in Brazil.

  • Operational TP: When tax function meets finance function

    March 28, 2014

    Frank Schoeneborn, head of global operational transfer pricing in the finance and accounting division at Merck Group with headquarters in Germany, looks at the practical problems in the implementation of operational transfer prices, illustrating the new tax risks stemming from these problems and showing how holistic management can be the solution.

  • India: Profit attribution to permanent establishments

    March 28, 2014

    Sanjay Sanghvi and Ashish Mehta of Khaitan & Co. analyse recent tax rulings dealing with the attribution of profits to permanent establishments, looking at what multinationals can do to avoid becoming embroiled in similar disputes in the future.

  • Indian transfer pricing changes take time to benefit taxpayers

    March 28, 2014

    Transfer pricing reforms, such as the introduction of safe harbour rules, have not reduced litigation or cut the compliance burden in India. And the government’s approach to the BEPS project could increase reporting requirements, explain Rajendra Nayak and Shweta Pai of EY.

  • Implications for maquiladoras of the 2014 Mexican tax reform

    March 28, 2014

    Ricardo León-Santacruz and Fernando Lujan of Sánchez-DeVanny Eseverri explain how the Mexican 2014 tax reform limits tax incentives and imposes new administrative burdens on the maquiladora sector, which is made up of wholly owned companies that process or assemble imported materials and parts into finished products for sale to the country of origin or other parts of the world.

  • Asia Transfer Pricing Focus 2014 now available

    March 14, 2014

    Leading transfer pricing advisers from KPMG in Australia, China, Hong Kong, India, Indonesia, Japan, Korea, Malaysia, New Zealand, the Philippines, Singapore, Taiwan, Thailand and Vietnam bring you insights and advice from across the region.

  • Swiss Focus 2014 now available

    March 07, 2014

    If one country has been a trailblazer in using the tax system to attract investment, it is Switzerland. But against a backdrop of international reforms and pan-European harmonisation, the scope for challenge of national regimes is increasing. Compliance initiatives such as the US FATCA, and the way it has been imposed on financial institutions and tax authorities around the world, highlight that outliers will no longer be tolerated. With this in mind, the 3rd edition of ITR's Swiss Focus brings you the latest domestic developments and analysis of how multilateral reforms are impacting taxpayers in Switzerland.

  • How to respond to rise of global audit activity

    February 26, 2014

    There is at least one certainty amid ongoing economic uncertainty: The frequency, complexity and intensity of tax audits are increasing throughout the globe. The heightened auditing activity represents a powerful response to widespread financial turmoil, believe Nancy Manzano and Bernadette Pinamont.

  • OECD seeks increased tax transparency from multinationals

    February 06, 2014

    The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations.

  • McKesson: A cautionary transfer pricing tale

    January 28, 2014

    Brad Rolph of Grant Thornton and Claire Kennedy of Bennett Jones review the decision of the Tax Court of Canada in McKesson Canada Corporation v HM The Queen, describe approaches to pricing factoring arrangements and highlight some of the key lessons for multinationals from this case.

  • 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.

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April 2014

Semeta’s legacy: The Commissioner’s greatest achievements

Algirdas Semeta, European Commissioner for Taxation, Customs Union, Audit and Anti-Fraud, has proven himself to be an ambitious reformer over the past four years. As Semeta approaches the end of his term, Salman Shaheen speaks to him about his greatest achievements, and what he wants to do before he leaves Brussels.

International Correspondents


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