New TP reforms in Ukraine likely to ramp up disputes and prolong audits The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pricing control. By Sophie Harding January 14 2015
China focuses on cross-border transactions in war on tax evasion The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. By Sophie Harding January 12 2015
McKesson saga continues with new filing by taxpayer McKesson has filed a supplementary memorandum of fact and law after the Court of Appeal deemed its initial memorandum too lengthy. The controversial transfer pricing case, involving a trial judge’s... By Sophie Harding January 08 2015
Indian CBDT launches new dispute resolution framework to silence critics The Central Board of Direct Taxes (CBDT) in India has introduced a new dispute resolution framework in an attempt to bring greater neutrality to tax dispute resolution and encourage multinationals... By Sophie Harding January 07 2015
India’s ITAT hands control back to tax authority in Vodafone case The Income Tax Appellate Tribunal (ITAT) has asked the income tax (IT) department to review its valuation of Vodafone’s taxable income. By Sophie Harding December 15 2014
Luxembourg releases paper on tax transparency amid “Lux leaks” controversy On December 10 the Luxembourg Ministry of Finance released proposals relating to tax transparency and advance rulings. This move comes as no surprise in the light of the recent “Lux... By Sophie Harding December 11 2014
Consensus over definition of intangibles and location savings increasingly unlikely Action 8 of the OECD’s BEPS project on the transfer pricing aspects of intangibles aims to achieve universal consensus over definition. By Sophie Harding December 10 2014
Attack on incentivised regimes will force tax industry to re-examine value chain manage... The risks versus people functions debate has long been a bone of contention in the tax world. The OECD’s BEPS project has signalled a drastic shift towards people functions, which... By Sophie Harding December 08 2014
Uncertainty around definition of key people functions could leave taxpayers in hot water One of the main concerns voiced on the first day of the Global TP Forum 2014 in Singapore was the definition of key people functions in relation to BEPS and... By Sophie Harding December 05 2014
SARS looks to APAs to create smoother TP audit process and tackle mispricing The South African Revenue Service (SARS) has announced it is considering introducing an advance pricing agreement (APA) system in the hope of creating a quicker, more effective transfer pricing audit... By Sophie Harding November 27 2014
