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Innovative case law on transfer pricing and illegality of normative instruction no. 243

A recent ruling from the Federal Regional Court of Appeals - third region in São Paulo (TRF3) may become important precedent for transfer pricing issues in Brazil.

November 10 2010
The new International Tax Review website is now live

The new www.internationaltaxreview.com includes a new publication and organises information in a clearer, logical way.

Ralph Cunningham, November 10 2010
A new era of transfer pricing in Indonesia

Douglas Fone, Global Partner of Transfer Pricing Associates, explores the implications of new transfer pricing guidelines in Indonesia

November 10 2010
Advance pricing agreements offer audit assurance

Shiv Mahalingham of Alvarez & Marsal (Taxand UK) deconstructs international approaches to APAs and explains how the agreements can help prevent unexpected adjustments, interest or penalties in transfer pricing audits.

November 10 2010
Resolution of FMC row is “tip of the iceberg” for disputes

On November 3, FMC Technologies (FMC), an oil and gas equipment services company, announced that it reached a resolution with the IRS about a proposed adjustment to the company’s federal income tax returns for the 2004 and 2005 tax years.

November 10 2010
OECD wants to better define the transfer pricing aspects of intangibles

The OECD’s Working Party 6, of the Committee on Fiscal Affairs, met yesterday in Paris to discuss a new project on the transfer pricing aspects of intangibles, which may lead to a revision of chapters six and eight of the transfer pricing guidelines (TPG).

November 10 2010
Kazakhstan chases one of its biggest taxpayers

The Kazakhstan tax authorities have made a $1.2 billion claim, including transfer pricing charges against the Karachaganak Petroleum Operating Group (KPO) for unpaid taxes between 2005 and 2008, a Reuters report revealed.

November 10 2010
Appellate courts decide not to apply GAAR to trigger Canadian withholding tax

In the last few months, the Canadian Federal Court of Appeal has twice ruled that the general anti-avoidance rule (GAAR) did not apply to cross-border transactions.

November 09 2010
Take part in the Latin America Client Services Poll

Executives responsible for the Latin America region often claim they have the most difficult job in the tax department. And this claim seems justified.

November 09 2010
Congress to debate new tax on foreign reinsurers

Foreign reinsurance companies may become targets in the US Congress's next effort to raise tax revenue to combat the rising national deficit.

November 09 2010

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