First bilateral safe harbour agreements could be signed within a year The OECD has revised its guidance to governments establishing safe harbours to push countries to set up bilateral agreements. However advisers say the efficiency of the system will depend on... By Emma Powell May 27 2013
India's Honda decision good news for import and export heavy industries A transfer pricing adjustment imposed on Honda’s Indian company, after fluctuations in the foreign exchange rate, has been overturned by the Delhi bench of the Income Tax Appellate Tribunal (ITAT). By Emma Powell May 22 2013
New Zealand companies risk losing interest deductions unless they review their non-resi... The New Zealand government has extended the scope of the thin capitalisation rules in the 2013 budget. Taxpayers will need to consider how these changes impact their debt to equity... By Emma Powell May 20 2013
Kodak India case clarifies definition of international transactions for TP A transfer pricing adjustment imposed on Kodak India, relating to its medical imaging business, has been overturned in the Mumbai bench of the Income Tax Appellate Tribunal (ITAT). By Emma Powell May 15 2013
Why the Australian budget will make taxpayers think twice about investing in the country The Australian government will reduce the thin capitalisation ratio of debt to equity as part of a raft of measures aimed at tackling base erosion and profit shifting, announced in... By Emma Powell May 13 2013
Zambian restrictions on export-derived capital may deter foreign investment The Zambian government has introduced measures to monitor the transfer of capital derived from the import and export of goods and services. By Emma Powell May 07 2013
How the OECD is advising tax authorities to select high-risk TP cases The OECD has released draft guidelines to help tax authorities identify high-risk transfer pricing arrangements that may require further scrutiny. The guidance should help taxpayers utilise their compliance resources more... By Emma Powell May 06 2013
Spanish taxpayers can challenge TP adjustments on capital gains transferred within EU Unrealised capital gains transferred from a Spanish company to another EU member state will no longer be taxed after a European Court of Justice (ECJ) ruling that taxation was contrary... By Emma Powell May 01 2013
Unclear tolerance bands put Indian taxpayers at greater risk of TP adjustments Indian taxpayers that import goods into the country and sell in bulk will be at greater risk of transfer pricing adjustments as the government has reduced the tolerance band for... By Emma Powell April 29 2013
Why Dutch guidance on interest deductibility of related party debt is inadequate The Dutch Ministry of Finance has released guidance on rules which limit interest on related party debt. However advisers have said taxpayers need further clarification on the deductibility of interest... By Emma Powell April 24 2013
