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Transfer Pricing

  • Editorial

  • OECD: How the OECD has passed on the intangibles baton

    Joe Andrus and Marlies de Ruiter joined the OECD’s Centre for Tax Policy and Administration (CTPA) at a critical time for Working Party No 6’s project on the transfer pricing aspects of intangibles. Sophie Ashley spoke to both of them to see how they picked up the threads of this important work.

  • Taxpayer’s view: Transfer pricing in financial services

    A financial services taxpayer discusses the strategic contours of transfer pricing in financial services and the challenges that the industry faces.

  • Global: A wave of uncertainty: Transfer pricing risk in the 21st century

    Despite trends towards simplification and clarification of rules, transfer pricing has become more complicated and the trend is leaning towards more uncertainty. Thomas Borstell and Loren Ponds, of Ernst & Young’s global transfer pricing team, explain how taxpayers can manage their transfer pricing risk in the changing environment.

  • Germany: Hypothetical arm’s-length testing and intellectual property

    Intellectual property (IP) is the major value driver in the global value chains of multinationals. Correspondingly, given its impact on profit allocations between group affiliates, it is also the most controversial transfer pricing issue both in tax legislation and tax audit practice. Yves Herve and Susann van der Ham of PwC focus on German particularities that arose out of new tax legislation from four years ago.

  • Hungary: Advance pricing arrangements in Hungary

    Though they are relatively new in Hungary, advance pricing arrangements (APA) are now quite popular among multinational companies. APAs can be obtained relatively quickly and cost efficiently, in close cooperation with a special team of tax authority professionals. Zoltán Lipták of Ernst & Young says the APA team of the tax authority has a track record of being flexible and cooperative with taxpayers.

  • Indonesia: Transfer pricing in Indonesia: A whole new ball game

    The global transfer pricing landscape has witnessed hectic activity in the last few years. Ay Tjhing Phan and Ravi Gupta of PwC explain how transfer pricing is emerging as the key weapon for Indonesian authorities to fulfil their tax collection objectives.

  • Luxembourg: Luxembourg as an investment centre

    Industrial groups have set up investment vehicles in Luxembourg to benefit from its extensive treaty network, the access to EU directives and the overall flexibility of the legal and tax environment offered by the country. Philippe Neefs and Sophie Boulanger of KPMG explain the transfer pricing aspects of this investment destination.

  • Russia: Overview of Russia's new transfer pricing rules

    Russia's new transfer pricing rules usher in a qualitatively new outlook in how the Russian tax authorities will consider intercompany transactions for tax purposes. Although some aspects resemble OECD principles, there are also significant deviations. Svetlana Stroykova, Ilarion Lemetyuynen, Adam Kosmala and Andrew Joshi of PwC provide an overview of the recent changes.

  • South Africa: The new South African transfer pricing rules may be risky

    More than two years have passed since it was first announced that the South African transfer pricing rules would undergo substantial redrafting. Jens Brodbeck and Carmen Gers of ENS – Taxand explain the development of the redrafting and its implications for taxpayers.

  • Taiwan: Self-initiated transfer pricing adjustments in Taiwan

    Related-party transactions can give rise to significant upward tax assessments in an increasing number of countries. Simon Huang of PwC explains the trend for self-initiated transfer pricing adjustments in Taiwan.

  • UK CFC changes: Extension of transfer pricing principles

    For a number of years the UK government has explicitly adopted a policy of reshaping the UK tax system so that it is more territorial in nature. Batanayi Katongera and Matthew Wentworth-May of Olswang explain the impact of the new UK CFC rules and their extended use of transfer pricing principles.

  • US: US developments aimed at efficiency

    There have been a number of important transfer pricing developments in the past 12 months in the US. Jim Fuller and David Forst of Fenwick & West summarise the most important changes.

International Correspondents