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Russia: Overview of Russia's new transfer pricing rules

Russia's new transfer pricing rules usher in a qualitatively new outlook in how the Russian tax authorities will consider intercompany transactions for tax purposes. Although some aspects resemble OECD principles, there are also significant deviations. Svetlana Stroykova, Ilarion Lemetyuynen, Adam Kosmala and Andrew Joshi of PwC provide an overview of the recent changes.

June 26 2012

India’s GST on course for further delays as Mukherjee leaves office

India may once again delay implementation of GST, but the effect of finance minister Pranab Mukherjee’s departure has yet to be seen.

Salman Shaheen, June 26 2012

Taxpayer’s view: Transfer pricing in financial services

A financial services taxpayer discusses the strategic contours of transfer pricing in financial services and the challenges that the industry faces.

June 26 2012

Hungary: Advance pricing arrangements in Hungary

Though they are relatively new in Hungary, advance pricing arrangements (APA) are now quite popular among multinational companies. APAs can be obtained relatively quickly and cost efficiently, in close cooperation with a special team of tax authority professionals. Zoltán Lipták of Ernst & Young says the APA team of the tax authority has a track record of being flexible and cooperative with taxpayers.

June 26 2012

US: US developments aimed at efficiency

There have been a number of important transfer pricing developments in the past 12 months in the US. Jim Fuller and David Forst of Fenwick & West summarise the most important changes.

June 26 2012

OECD: How the OECD has passed on the intangibles baton

Joe Andrus and Marlies de Ruiter joined the OECD’s Centre for Tax Policy and Administration (CTPA) at a critical time for Working Party No 6’s project on the transfer pricing aspects of intangibles. Sophie Ashley spoke to both of them to see how they picked up the threads of this important work.

June 26 2012

Global: A wave of uncertainty: Transfer pricing risk in the 21st century

Despite trends towards simplification and clarification of rules, transfer pricing has become more complicated and the trend is leaning towards more uncertainty. Thomas Borstell and Loren Ponds, of Ernst & Young’s global transfer pricing team, explain how taxpayers can manage their transfer pricing risk in the changing environment.

June 26 2012

Germany: Hypothetical arm’s-length testing and intellectual property

Intellectual property (IP) is the major value driver in the global value chains of multinationals. Correspondingly, given its impact on profit allocations between group affiliates, it is also the most controversial transfer pricing issue both in tax legislation and tax audit practice. Yves Herve and Susann van der Ham of PwC focus on German particularities that arose out of new tax legislation from four years ago.

June 26 2012

Essar’s accounts feel sales tax pain

An unresolved sales tax liability related to its Vadinar refinery in the Indian state of Gujarat clouded the annual accounts presentation by Essar Energy, the natural resources company, just as another decision related to the issue went against it in the courts.

Ralph Cunningham, June 26 2012

Taiwan: Self-initiated transfer pricing adjustments in Taiwan

Related-party transactions can give rise to significant upward tax assessments in an increasing number of countries. Simon Huang of PwC explains the trend for self-initiated transfer pricing adjustments in Taiwan.

June 26 2012

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