The development of clear transfer pricing rules and relevant training of tax officers is becoming an emergency in Albania, believe Alexandros Karakitis of Ernst & Young Albania and FYROM and Anisa Jasini of Ernst & Young Albania
Carlos Casanovas and Gustavo Scravaglieri of Ernst & Young Argentina explain the recharacterisation issues under the Argentine Transfer Pricing rules
A decree in March 2011 should be seen in the broader context of the German tax authorities focusing more and more on the transfer pricing for intra-group financing arrangements, explain Lorenz Bernhardt and Claudia Kühnlein of PwC
The Luxembourg intra-group financing market has recently adapted to new transfer pricing rules, which have significantly changed the documentation requirements for such intra-group financing transactions structured through Luxembourg, explain Philippe Neefs and Sophie Boulanger of KPMG
The sweeping reform of the corporate income tax legislation of the Former Yugoslav Republic of Macedonia (FYROM) in 2009 makes transfer pricing audits a major area of focus for targeting higher corporate tax revenues, report Alexandros Karakitis of Ernst & Young Albania and FYROM and Dusko Stevceski of Ernst & Young FYROM
The action that Portugal has to take in the coming years to fix its economy mean there will be more scrutiny of transfer pricing from the tax authorities, believe Leendert Verschoor and Gonçalo Moreira of PwC Portugal. They recommend that taxpayers should review their transfer pricing policies now to prepare for this.
Batanayi Katongera and Natasha Kaye of Olswang suggest that while optimising your tax structure before developing intellectual property (IP) is a fundamental in the UK, taxpayers need to regularly consider both the ownership and exploitation of its IP.
Kenneth Clark and Ronald Schrotenboer of Fenwick & West explain that although the Supreme Court’s decision in Mayo may lead the IRS to argue that it has significant discretion, taxpayers still have a number of tools left to defend the traditional definition of the arm’s-length standard.