Why India’s draft safe harbour rules may need work before gaining popularity with taxpa... The Indian Central Board of Direct Taxes has issued draft safe harbour rules that provide taxpayers with a margin under which their transfer prices would be automatically accepted by the... By Emma Powell August 15 2013
General Motors case reinforces Indian taxpayers’ right to use foreign entities as teste... In the first case to reference the UN manual since the Indian government formally adopted it, taxpayers can be more confident about using a foreign entity to test whether a... By Emma Powell August 13 2013
How transfer pricing adjustments can impact indirect tax payments Taxpayers must be more aware of the impact transfer pricing adjustments are having on their indirect tax liabilities, advisers have said. By Emma Powell August 08 2013
How taxpayers can identify comparables in developing markets Taxpayers in developing markets can find it difficult to find reliable comparables to benchmark their transfer pricing. However, the UN Practical Manual on Transfer Pricing for Developing Countries demonstrates why... By Emma Powell August 07 2013
OECD’s plan to simplify documentation requirements could have the opposite effect The OECD has released a white paper on transfer pricing documentation, which proposes a two-tier approach that would require taxpayers to submit a global master file along with country-specific transaction... By Emma Powell August 01 2013
How to build a simpler and more harmonised operational transfer pricing system Taxpayers are demanding better automated and centralised systems for calculating their transfer pricing. However there is still some way to go before the use of harmonised operational models become standard... By Emma Powell July 30 2013
Ghana Revenue Authority to launch TP unit The Ghana Revenue Authority (GRA) is planning to launch a transfer pricing unit within its large taxpayers office. The launch had been scheduled for the end of June but no... By Emma Powell July 26 2013
SARS increases challenges to transfer pricing of intercompany services The South African Revenue Service (SARS) is challenging more taxpayers on their intercompany services. South African taxpayers must consider whether the services they provide to foreign related parties have a... By Emma Powell July 24 2013
How to survive a transfer pricing audit in Indonesia New guidelines for Indonesian officials conducting transfer pricing audits are now in force. The guidance puts pressure on taxpayers to provide more detailed evidence about their related-party transactions when subject... By Emma Powell July 16 2013
How the French tax administration is selecting transfer pricing cases for audit The French Directorate for Public Finance has published its 2012 activity report, which shows tax and penalties gained after audit have risen by 10%. By Emma Powell July 11 2013
