Japanese taxpayers may now be subject to joint transfer pricing and corporate tax audits Taxpayers in Japan may now have their transfer pricing included in a single corporate tax audit after the National Tax Authority clarified procedures to be taken during tax audits. By Emma Powell March 14 2013
Danish tax authority demands $1 billion from Microsoft over undervaluing of software The Danish tax authority, SKAT, has demanded around DKK 5.8 billion ($1 billion) in back taxes from Microsoft Denmark over the sale of software rights to its Irish subsidiary, according... By Emma Powell March 12 2013
Germany proposes to limit participation exemptions for hybrid instruments The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. By Emma Powell March 07 2013
Korea clarifies arm’s-length calculation of intercompany guarantee transactions The Korean government has issued guidance on the calculation of the arm’s-length price of guarantee fees for intercompany-guarantee transactions in response to a growing number of disputes involving companies receiving... By Emma Powell March 05 2013
South Africa limits interest deductibility on related party debt New limits will be placed on the deductibility of interest on related party debt under the South African budget 2013, announced yesterday. By Emma Powell February 28 2013
HMRC is exchanging unilateral APA information with treaty partners HMRC is exchanging the terms of its unilateral advance pricing agreements (APA) with UK tax treaty partners. The measure is part of the revenue’s drive towards greater transparency and began... By Emma Powell February 26 2013
France reassesses cooperative list of tax treaty states The French government will reassess how effectively information is exchanged with bilateral treaty partners to reduce the loss of revenue through cross border transactions. By Emma Powell February 21 2013
Taxpayers need cost-sharing law in Russia to combat shared service disputes Taxpayers need cost-sharing provisions to be written into Russian tax legislation to combat an increased risk of dispute over the allocation of shared service costs. By Emma Powell February 19 2013
Basel III confusion in transfer pricing creates double taxation risk A lack of international consensus on the treatment of liquidity buffers, required under Basel III, is leaving banks exposed to the risk of double taxation. By Emma Powell February 07 2013
Shell India tax dispute could lead to greater uniformity of valuation methods Shell India will challenge a claim by the Indian tax authorities that it undervalued shares issued to a foreign subsidiary on the grounds that the order is contrary to tax... By Emma Powell February 07 2013
