This content is from: Australia Authorities aim to stop multinationals pushing losses into Australia Transfer pricing has long been an area of focus for the Australian Taxation Office. The ATO recently issued a taxpayer alert advising taxpayers that shifting of business losses into Australia will be under increased s... November 26 2008
This content is from: European Union More countries comply with EU documentation rules Slovakia and Spain have both introduced amendments to bring their legislation into line with the EU transfer pricing forum’s approach to documentation. November 26 2008
This content is from: Transfer Pricing OECD and business community discuss transfer pricing guidelines The OECD held a consultation on November 19 2008 with business commentators on the topics of comparability and profits under OECD transfer pricing guidelines for multinational enterprises and tax administrations November 26 2008
This content is from: United Kingdom HMRC aims to slash transfer pricing cases Diane Hay, chairwoman of Her Majesty’s Revenue & Customs’ transfer pricing board at HMRC would like to halve the amount of transfer pricing cases that HMRC takes up, concentrating resources on higher risk cases November 26 2008
This content is from: Taiwan New Taiwanese safe harbour ruling and its implications On November 6 2008, the Taiwan Ministry of Finance released the final ruling to the modifications of the safe harbour ruling (ruling number 09704555160). The finalised ruling modifies the conditions which must be met ... November 26 2008
This content is from: South Africa South Africa warns of action over transfer pricing abuse The South African Revenue Service has said it will crack down on transfer pricing abuse amid concerns that multinationals are using the method to boost balance sheets. November 26 2008
This content is from: Transfer Pricing Economic issues in the OECD draft report on business restructurings Paul Flignor and Alan Granwell of DLA Piper investigate four of the major economic considerations for companies as a result of the OCED draft report. November 25 2008
This content is from: China Zero hour on transfer pricing in China China was supposed to have mandatory documentation as of January 1 2008 but the final guidelines are still awaited. Here, Glenn DeSouza summarises the hot issues and shares strategies on dealing with thin capitalisati... November 25 2008
This content is from: China China service fees charged between parent and subsidiaries examined New guidance from China’s State Administration on Taxation (SAT) means that parent companies will now need signed agreements with subsidiaries for service costs to be deductible. November 25 2008
This content is from: France French tax authorities reject traditional transaction methods The French tax administration is increasingly turning to the transactional net margin method of determining an arm's length price. Jean-Luc Trucchi argues that rapidity and efficiency should not be used as an excuse f... November 21 2008
This content is from: Hungary Hungary gets tough on transfer pricing Hungary’s tax authorities have told taxpayers to comply with the country’s transfer pricing regime or risk facing large penalties November 19 2008
This content is from: China South-East Asia looks to tighten transfer pricing rules Countries in South-East Asia are introducing or reforming their transfer pricing rules to increase revenues and attract foreign investment November 19 2008
This content is from: France Marketing intangible assets can lead to exit taxes In France, the concept of marketing intangible assets has led the tax authorities to imposing taxes on companies. Jean-Luc Trucchi explains what is happening. November 18 2008
This content is from: United Kingdom Business restructuring is under the transfer pricing spotlight Batanayi Katongera of Thomson Reuters warns corporations everywhere that business restructurings are under more scrutiny than ever before in light of the OECD discussion draft on the topic. November 18 2008
This content is from: Brazil Advisers criticise profit margin in resale price less profit method Brazilian transfer pricing rules adopt fixed profit margins in methods applicable to import transactions. Fabia Moreira Azevedo of Machado Associados explains why many are critical of the percentage profits margins al... November 18 2008
This content is from: Thailand Thai court changes rule on share values Transfer pricing advisers in Thailand are warning companies using a specific holding company investment structure that traditional treatment of their tax liability is changing November 12 2008
This content is from: Transfer Pricing Global economic crisis will effect transfer pricing in Uganda As world markets plunge, even one of the world’s poorest nations is beginning to worry about the implications for them, and is turning to transfer pricing revenues as a means of survival November 11 2008
This content is from: New Zealand Incoming government puts off transfer pricing changes in New Zealand New Zealand’s new government sees transfer pricing as a critical piece in the country’s international tax regime, but is unlikely to tighten the current rules amid a struggling economy, a leading professional says November 11 2008
This content is from: United States Obama will change US transfer pricing Advisers expect President-elect Obama's administration to put changes to transfer pricing rules high on its list of priorities when he takes office November 11 2008
This content is from: India India should introduce APAs and change data rules Rahul Mitra of PricewaterhouseCoopers outlines the flaws in the Indian transfer pricing regime and explains why changes need to be made to support multinational companies operating in the country November 10 2008
This content is from: Transfer Pricing Israel clarifies approach to APAs The Israeli Tax Authority (ITA) recently released the Income Tax Circular No. 3/2008 concerning transfer pricing November 05 2008
This content is from: United States IRS plans action against transfer pricing breaches The Internal Revenue Service wants to tighten transfer pricing rules to stop multinational companies with US operations using them illegally to cut their tax bills November 04 2008
This content is from: United States Ceteris hires three and expands practice into Boston Ceteris, a global economic consulting firm that provides transfer pricing, intellectual property and valuation services has expanded into the Boston area by hiring Jill Weise and Mark Bronson as managing directors, an... November 04 2008
This content is from: Russia Russia must strengthen transfer pricing rules Russia’s weak transfer pricing regime is hindering the countries development and making the country less attractive to foreign investment, says a leading professional firm November 03 2008
This content is from: India Industry body demands changes in India Indian employers have called on the government to clarify transfer pricing rules and introduce an advance pricing agreement programme to encourage investment November 03 2008
This content is from: Transfer Pricing Kazakhstan to relieve transfer pricing burden on mining industry Relaxing transfer pricing regulations is one method under consideration to assist Kazakh miners in trouble November 03 2008
This content is from: European Union Dutch introduce welcome changes to MAP Eduard Sporken and Kelly Bouman of KPMG Meijburg & Co explain how reform of the MAP procedure in the Netherlands is a positive step November 01 2008
This content is from: United States Award winners on display International Tax Review's Americas Awards took place in New York on October 2 November 01 2008
This content is from: Europe New double taxation treaties under negotiation Cyprus has a considerable number of double tax agreements with various countries. By ITR Correspondent November 01 2008
This content is from: European Union New regulations on APAs in Portugal Eduardo Goldszal and Catarina Breia of KPMG in Portugal explain the country's new regulations concerning APAs. November 01 2008
This content is from: Ireland Under lock and key: Downturn forces tax directors to safeguard cash pile In economic downturns company bosses search for as many ways as possible to cut costs and bring in cash. Joanna Faith discovers the real value of the tax function in uncertain times. November 01 2008