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Transfer Pricing
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Roman Blazhko
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Colin Farrell and Matthew Mui PwC Fighting tax avoidance has become a common effort of the international tax community to prevent companies from eroding the tax base of the source or resident countries and paying tax nowhere. And China is no exception. During 2012, China witnessed a significant growth in its tax collection through anti-tax avoidance efforts. According to the latest statistics published by the State Administration of Taxation (SAT), the 2012 total tax collection contributed from anti-tax avoidance operations amounted to RMB34.6 billion (around US$5.6 billion), representing a year-on-year growth of 45% over 2011, and 74 times the 2005 amount. The Chinese tax authorities initiated 233 anti-tax avoidance cases in 2012. Among the 175 settled cases, the average amount of tax collected per case was RMB26.2 million, and the largest single sum of tax collection amounted to RMB 843 million. Nine cases reclaimed tax of more than RMB100 million and 59 cases reclaimed more than RMB10 million.
Sponsored Features
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Sponsored by insightsoftwareJoin Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations
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Sponsored by BDO IndiaJoin ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
Special Focus
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Sponsored by EY Central AmericaAntonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
Local Insights
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks
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Sponsored by VdAThe regime has modernised the taxation of employee equity, but several lingering shortcomings leave room for enhancement, say João Riscado Rapoula, Miguel Gonzalez Amado, and Ana Francisca Ribeiro of VdA
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Sponsored by PwC ChileSandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions