Transfer Pricing

Archive: Transfer Pricing

This content is from: Transfer Pricing

India rules on profits attributed to permanent establishments

A tribunal in India has ruled that payment of the arm’s length price to a dependent agent does not remove the tax liability of a foreign entities’ permanent establishment in India.
February 25 2009
This content is from: India

Honeywell loses Indian appeal

An Indian automotive company has lost its appeal against the Indian transfer pricing authorities over the method used for carrying out transactions with its various entities.
February 25 2009
This content is from: United States

Complex cost sharing regulations offer many benefits

The cost sharing regulations introduced recently in the US are extremely complicated but offer taxpayers many planning benefits according to one senior transfer pricing adviser.
February 25 2009
This content is from: Transfer Pricing

Conference comments on business restructuring

The issue of control was a key talking point at a conference on the transfer pricing aspects of business restructuring in London last week
February 25 2009
This content is from: United States

The implications of the credit crunch for intercompany loans

Reliance on on the applicable federal rate (AFR) safe haven of section 1-482.2 of the Internal Revenue Code is not likely to address the need to comply with both US transfer pricing regulations and the expectation of ...
February 24 2009
This content is from: India

Indian IT companies want new rules

The head of the organisation that represents the information technology-business process outsourcing industry in India has called on the government to introduce more generous transfer pricing rules
February 19 2009
This content is from: Brazil

How import pricing works in Brazil

According to the explanatory statement of law number 9,430/96, which governs Brazilian transfer pricing rules, the lawmaker is focusing on avoiding tax evasion by means of undercharging exports or overcharging imports...
February 17 2009
This content is from: Uruguay

Uruguay issues further guidelines on transfer pricing

Uruguay has finally introduced guidelines on the application of transfer pricing rules, over two years after the laws were enacted.
February 17 2009
This content is from: Australia

ATO produces guidance on Roche Products case

Tax professionals in Australia agree with the authorities’ view of the value of the Administrative Appeals Tribunal’s judgement in the Roche Products case, though some would have preferred a more comprehensive ruling ...
February 11 2009
This content is from: France

Event highlights European business restructuring challenges

Taxpayers were warned of the UK government’s dual approach to disregarding transactions at a transfer pricing conference in New York last week.
February 10 2009
This content is from: United Kingdom

Hay wants better understanding between business and governments

Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HM Revenue & Customs in the UK tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authori...
February 05 2009
This content is from: Switzerland

NERA opens in Geneva

The new office that NERA Economic Consulting, a global provider of economic advice and analysis in business, legal, and regulatory matters, is opening in Geneva will focus on transfer pricing and intellectual property...
February 04 2009
This content is from: Australia

Australia and Isle of Man agree on dispute resolution in transfer pricing

Australia and the Isle of Man have signed up to a mutual agreement procedure in transfer pricing disputes
February 03 2009
This content is from: Transfer Pricing

Madrian joins Ceteris in Silicon Valley

Global economic consulting firm Ceteris has expanded its practice into the Silicon Valley area and hired Mark Madrian as a managing director to lead the Pacific Northwest region
February 03 2009
This content is from: Brazil

The consequences of not applying transfer pricing methods

On December 31 of each year, Brazilian legal entities must calculate transfer pricing adjustments in order to determine the taxable bases of the corporate income tax (IRPJ) and the social contribution on net profit (C...
February 02 2009
This content is from: South Korea

Korea introduces contemporaneous documentation requirements and penalty rules

The new transfer pricing documentation-related penalty rules in the law for the coordination of international tax affairs (LCITA) are effective from December 26 2008. Under the new rules, a Korean taxpayer with relate...
February 02 2009
This content is from: Canada

Tax professionals try to be positive about OECD and business restructuring

In September, the OECD issued a consultation paper on the transfer pricing aspects of business restructuring. Ahead of the deadline for submissions, Joanna Faith finds out how tax professionals have reacted to the draft
February 01 2009
This content is from: United Kingdom

UK transfer pricing chief quits HMRC
February 01 2009
This content is from: Hong Kong SAR

Transfer Pricing Associates strengthens Asia team
February 01 2009
This content is from: United Kingdom

AstraZeneca fights HMRC over transfer pricing
February 01 2009
This content is from: India

Indian court rules against Coca-Cola
February 01 2009

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