This content is from: Singapore Singapore proposes transfer pricing guidance for loans and services The Inland Revenue Authority of Singapore (IRAS) has published a draft supplementary circular to provide guidance on the application of the arm’s length principle to related party loan and service arrangements. October 28 2008
This content is from: China China’s tax restructure will hit large firms The Chinese State Administration of Taxation (SAT) is to be restructured to improve transfer pricing rules and enhance the tax administration of the country’s larger companies October 28 2008
This content is from: Japan Hiroaki Furuya joins Gardere The addition of Hiroaki Furuya to Gardere’s international tax and transfer pricing (ITTP) practice strengthens an already robust team October 28 2008
This content is from: Belgium How to survive a transfer pricing audit in Belgium Leslie Van den Branden of De Witte Viselé Associates explains the environment of transfer pricing audits in Belgium October 28 2008
This content is from: United Kingdom HMRC look to transfer pricing to increase their tax revenues The House of Commons public accounts committee report on the management of large business corporation tax stated that half the growth in global trade comes from transactions between subsidiaries of multinational compa... October 28 2008
This content is from: Italy Italian transfer pricing rules used to demonstrate tax ethics problem The fact that Italy criminalises transfer pricing conflicts was a major example used to demonstrate the problems with asking tax practitioners to comply with all tax laws around the world October 28 2008
This content is from: Transfer Pricing Gardere adds transfer pricing managing director An experienced Japanese professional has joined the Texas firm October 28 2008
This content is from: Sweden Transfer pricing is top of the agenda in Sweden Sweden tightens transfer pricing regulation October 28 2008
This content is from: China Thin capitalisation adopted in China The introduction of thin capitalisation to the new Chinese Corporate Income Tax Law (CIT) was celebrated by many borrowing enterprises, but many will be left disappointed by its lack of clarity October 28 2008
This content is from: Argentina Taxpayer wins Argentine verdict on technology transfer payments Daniel Rybnik of EnterPricing says that taxpayers in Argentina should be aware of the different treatment of transfer pricing policies based on variable and fixed factors October 21 2008
This content is from: Colombia Double taxation treaty between Spain and Colombia approved The new tax treaty between Spain and Colombia contains transfer pricing implications. Here Moises Curiel and Diego Gonzalez-Bendiksen of Baker & McKenzie outline the treaty elements. October 21 2008
This content is from: Brazil New Brazilian rules clarify how to obtain changes in profit margins Carlos Eduardo Costa MA Toro and Carlos Eduardo de Biasi of Zilveti Sanden Advogados believe that new rules on requesting a reduction in the presumed profit margin are a step forward for Brazilian transfer pricing October 21 2008
This content is from: Qatar OECD defends approach to business restructuring Mary Bennett, head of the tax treaty and transfer pricing division at the OECD, has defended the discussion draft on the transfer pricing aspects of business restructuring October 21 2008
This content is from: South Korea Korea proposes penalty relief for taxpayers maintaining contemporaneous documentation The Ministry of Strategy and Finance announces various proposed amendments to tax laws which include provisions to provide penalty relief to taxpayers maintaining contemporaneous transfer pricing documentation. October 16 2008
This content is from: United States Korean National Tax Service releases APA annual report The Korean National Tax Service recently published its 2007 APA annual report, Henry An of Samil PricewaterhouseCoopers describes some of the key elements of the report October 14 2008
This content is from: United States Mandatory arbitration makes debut in Canada-US treaty Santino Di Libero of Gowling Lafleur Henderson believes the inclusion of mandatory arbitration in the fifth protocol to the Canada-US treaty will help the competent authority process between the two countries October 14 2008
This content is from: Venezuela Transfer pricing is slow to catch on in South America Transfer pricing rules have been in place in certain South America jurisdictions for many years but so far, little action has been taking by either taxpayers or the aurthorities. October 13 2008
This content is from: European Union PricewaterhouseCoopers hires tax litigation expert Ebrahim Ali, has joined PricewaterhouseCoopers Legal's tax litigation team October 13 2008
This content is from: China NERA Economic Consulting expands presence in China NERA Economic Consulting opens Beijing office October 13 2008
This content is from: Ireland Forest uses transfer pricing to channel $2 billion through Ireland Forest Laboratories, a US pharmaceutical company, used transfer pricing methods to channel more than $2 billion through its Irish operation in the last financial year October 13 2008
This content is from: Transfer Pricing Namibian mining royalties to be extended beyond transfer pricing cases The Ministry of Mines and Energy in Namibia wants to amend a section of the existing Minerals Act to impose a royalty on all minerals mined or discovered during prospecting operations October 13 2008
This content is from: Turkey Key issues of Turkish advance pricing agreements Ramazan Biçer, senior transfer pricing specialist in the transfer pricing division of the Turkish revenue administration, highlights the key issues of advance pricing agreements in Turkey October 07 2008
This content is from: China KPMG adds to transfer pricing practice in China KPMG’s global transfer pricing services group in China is expanding with a series of new hires which will take its total number of full time professionals to more than 100 October 07 2008
This content is from: Netherlands The Netherlands revamps mutual agreement procedure process The Netherlands has issued a new mutual agreement procedure (MAP) in a move that will make avoiding double taxation more accessible and transparent for taxpayers. October 07 2008
This content is from: Ecuador New constitution gives further powers in Ecuador On September 28 2008 Ecuador's president, Rafael Correa won a referendum on a new constitution that provides significant new powers, including some linked to transfer pricing. October 07 2008
This content is from: United States Using credit default swaps to price intercompany loan guarantees Harlow Higinbotham and Stuart Harshbarger of NERA Economic Consulting discuss the use of credit default swaps to price intercompany loan guarantees. October 06 2008
This content is from: United States Anticipating business restructuring documentation requirements John Hughes of Mayer Brown explains how taxpayers must raise the bar on transfer pricing documentation to stay inline with the new OECD discussion draft. October 05 2008
This content is from: Canada CRA maintains focus on transfer pricing audits Christopher Steeves of Fraser Milner Casgrain analyses the recent CRA report on the mutual agreement procedure program. October 04 2008
This content is from: United States Reconsidering the Mexican Maquiladora paradigm Mauricio Hurtado and Fred Barrett of PricewaterhouseCoopers delve into restructuring issues for traditional Maquiladoras in Mexico October 04 2008
