China shows signs of OECD guideline acceptance China has demonstrated a certain degree of resistance towards the OECD guidelines and adopting international policies but it is beginning to show signs of acceptance. By Sophie Harding August 06 2014
Incomplete intangibles guide suggests OECD’s September deadline was overly ambitious On July 23, Michelle Levac, chair of Working Party No 6, announced that the revised chapter on intangibles, to be released in September, will not be final guidance. By Sophie Harding August 04 2014
EC investigations suggest weakening control of tax authorities The European Commission (EC) announced recently that it has opened three in-depth investigations into supposed sweetheart deals between the tax authorities of Ireland, the Netherlands and Luxembourg with Apple, Starbucks... By Sophie Harding July 30 2014
Controversial inversions driven by lack of US tax reform Inversion deals between companies such as Medtronic and Covidien, and failed attempts such as Pfizer’s desired takeover of AstraZeneca, have brought inversion transactions to the forefront of global tax issues. By Sophie Harding July 28 2014
Reed Elsevier’s Paul Morton discusses the most debated transfer pricing issues Paul Morton, head of group tax at Reed Elsevier, addresses the transfer pricing topics hitting the headlines in an exclusive interview with TPWeek and provides an insight into Reed Elsevier’s... By Sophie Harding July 17 2014
Finnish TP ruling undermines OECD guidelines The Finnish Supreme Administrative Court has ruled against the Finnish Tax Administration on the grounds that tax law reclassification can only be made under general anti-avoidance provisions and not transfer... By Sophie Harding July 16 2014
How Jaitley’s budget could impact transfer pricing in India this year Arun Jaitley, India’s Finance Minister, will announce India’s annual budget on July 10. With so many recent developments in transfer pricing, the budget is expected to bring more change for... By Sophie Harding July 07 2014
Fiat’s Andrea Bonzano talks BEPS, formulary apportionment and the profit split method Andrea Bonzano, head of tax at Fiat, discusses the pros and cons of different transfer pricing methods in an interview with TPWeek, and provides his views on BEPS and US... By Sophie Harding June 29 2014
Marzen Aluminum ruling based on structuring rather than pricing The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. By Sophie Harding June 25 2014
ITAT overrules TPO’s adjustment concluding taxpayer was simply a mediator for parent co... The Income-Tax Appellate Tribunal (ITAT) in Delhi has overruled a transfer pricing adjustment, finding the taxpayer’s activity was low risk and consisted primarily of agency services. By Sophie Harding June 22 2014