This content is from: Poland How exchange rate differences arise in related-party transactions in Poland Taxpayers may have to explain why they used a certain exchange rate in related-party transactions. If they cannot they could face higher tax bills, explain Jaroslaw Bieronski and Bartlomiej Bialy of Soltysinski Kaweck... December 23 2008
This content is from: United Kingdom KPMG recruits for transfer pricing practice Stephanie Pantelidaki will join KPMG’s transfer pricing team in London as an associate partner December 22 2008
This content is from: China China issues disclosure forms Taxpayers in China will need to submit nine transfer pricing disclosure forms when they file their 2008 tax return next year December 19 2008
This content is from: India Indian authorities tell officers to apply transfer pricing rules in bank-branch dealings The banks' compliance burden is set to increase after an order from CBDT December 19 2008
This content is from: United States Global documentation burden increases The burden of keeping up with transfer pricing documentation requirements is becoming one of the biggest challenges for multinational corporations, with some taxpayers having to prepare upwards of 500 transfer pricing... December 17 2008
This content is from: Transfer Pricing How the recession will have an impact on comparables selection and documentation It is now clear to tax authorities and taxpayers, says Pamesh Sharma of Thomson Reuters, that the economic downturn will offer unique challenges to the arm’s-length standard and the continuing search for evidence to s... December 17 2008
This content is from: Transfer Pricing OECD approach to PEs: When arm’s length agent compensation is enough On July 17, the OECD issued its final report on the attribution of profits to permanent establishments, reaffirming the “separate entity approach” that hypothesises a permanent establishment (PE) as a separate and dis... December 16 2008
This content is from: United Kingdom Loan relationship reforms published for UK connected companies HM Revenue and Customs in the UK has released draft legislation that amends the corporation tax rules on late-paid interest between connected companies. December 16 2008
This content is from: Brazil Decision on basket approach creates unfavourable Brazilian precedent One of the several controversial aspects of Brazil's transfer pricing legislation is the possibility for taxpayers to take into account the “basket approach” criterion to calculate the parameter price. Henrique de Fr... December 16 2008
This content is from: Poland Poland requires financial statement disclosure for related parties The amendment to the Polish Accounting Act of March 18 2008, part of which came into force on August 22 2008, has changed the scope of information and data to be provided in additional information to the financial sta... December 15 2008
This content is from: Malaysia New arm’s length provision and advance pricing arrangements come to Malaysia In less than a month, section 140A will be introduced into Malaysia's tax legislation. This new section in the income tax act, 1967 will specifically target transfer pricing issues. These changes will be effective fro... December 15 2008
This content is from: United Kingdom UK transfer pricing chief quits HMRC Diane Hay has left HM Revenue and Customs December 11 2008
This content is from: Poland New Polish regulations eliminate double tax in certain transactions On November 24 2008 the Polish President signed the act of November 6 2008 amending (among other things) the corporate income tax act. The new act introduces regulations concerning transfer pricing issues that will al... December 10 2008
This content is from: Canada More Canadian taxpayers choose APAs The Canada Revenue Agency (CRA) recently released its annual report on advanced pricing agreements (APAs) covering the fiscal period ending March 21 2008. December 10 2008
This content is from: Transfer Pricing Seize the chance to comment on business restructuring A London event in February gives taxpayers the opportunity to contribute to the debate on the OECD's discussion draft on business restructuring December 10 2008
This content is from: India India to say no to transfer pricing reform Reforming transfer pricing in India will not be top of the agenda in next year’s budget, despite fears that the present system is too aggressive and a hindrance to business development. December 10 2008
This content is from: Philippines Transfer pricing not a priority for the Philippines' new commissioner The Philippines' wait for transfer pricing regulations is set to continue with the appointment of a new tax chief who, says tax professionals, is in no hurry to introduce any new rules. December 10 2008
This content is from: Germany New rules in German transfer pricing Angelika Thies of CMS Hasche Sigle in Munich, Germany explains the latest developments in German transfer pricing December 10 2008
This content is from: Greece Greece gets documentation rules Following an amendment to the draft law entitled “Market Supervision Authority and other provisions” submitted to the Greek parliament, rules are being introduced for auditing transfer pricing in inter-company transac... December 04 2008
This content is from: Transfer Pricing Developing countries warned on transfer pricing abuse Poor countries have been warned against giving too many tax incentives and allowing transfer pricing abuses in their bid to encourage international companies to invest in their economies December 03 2008
This content is from: Australia Australia predicts boost in APAs next year Advanced pricing arrangement programmes in Australia are expected to increase next year as taxpayers look for more certainty and the tax office enhances its transfer pricing review and enforcement activity December 03 2008
This content is from: China Officials discuss how transfer pricing will change in China Chinese officials finally announce details of the changes to be made to transfer pricing rules December 03 2008
This content is from: Greece Greece implements OECD standard Greece has introduced new laws to bring its transfer pricing documentation legislation more into line with OECD standards December 03 2008
This content is from: United States Using transfer pricing as a repatriation tool during economic downturns During economic downturns, US-based multinationals may find themselves wanting to repatriate cash from foreign subsidiaries. Under such circumstances, transfer pricing may provide a useful mechanism to achieve this in... December 03 2008
This content is from: United Kingdom UK reforms loan rules for connected companies HM Revenue and Customs is to introduce corporate tax legislation that amends the loan relationships rules affecting connected companies December 03 2008
This content is from: Canada Canadian courts shed light on transfer pricing cases John Yuan and Deborah Toaze of McCarthy Tétrault discuss what taxpayers can learn from the first court verdicts in transfer pricing cases in Canada December 01 2008
This content is from: Spain Legislative developments By Ramón López de Haro and Mario Ortega Calle of Garrigues December 01 2008
This content is from: European Union Why transfer pricing matters in asset management By Emmanuel Llinares, Takefumi Suzuki and Sylvain Gilibert of NERA December 01 2008
This content is from: Germany German transfer pricing: pioneering or isolated? Lorenz Bernhardt and Loek de Preter of PricewaterhouseCoopers describe the main elements of a new ordinance and evaluate how the rules might be mirrored in the recent OECD discussion draft on business restructurings December 01 2008
This content is from: Japan Technology and marketing intangibles in Japan By Jon Jenni and Karl Gruendel of Ernst & Young Shinnihon Tax December 01 2008
This content is from: United States How to value transferred know-how and IP after a merger By Alexander Vögele, Wolf Witt and Stuart Harshbarger of NERA December 01 2008
This content is from: European Union How the OECD will impact IP and transfer pricing By Graham Poole and Emmanuel Llinares of NERA December 01 2008
This content is from: United States Migration to brand management centre can work By Alexander Vögele, Hendrik Fügemann and Stuart Harshbarger of NERA December 01 2008
