This content is from: Japan Hay stresses need for closer cooperation Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HMRC tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority and part of working par... April 30 2009
This content is from: Argentina Firms show sparkle in tax planning Uncertainty about the fate of the global economy and a more uncompromising attitude generally from tax authorities around the world has encouraged taxpayers to go to tax planning with long-standing reputations. As a r... April 30 2009
This content is from: United Kingdom First UK verdict focuses on appropriate outcome Mark Atkinson and Richard Coombes of Deloitte in London believe that the decision in the first UK transfer pricing case in more than 20 years shows that taxpayers need a good reason to base a transaction in a low-tax ... April 30 2009
This content is from: United States How APAs fit into today's regulatory landscape Advanced pricing agreements can position businesses better in this environment, say Mark Nehoray and Reiko Ishii of Deloitte April 30 2009
This content is from: India Getting transfer pricing right in the recession and beyond In a recession transfer pricing risk is intensified as tax authorities scrutinise intercompany payments rigorously in an attempt to recover cash. Joanna Faith finds out what tax departments can do to improve their pos... April 30 2009
This content is from: India Tribunals have final say in India A recent court ruling has determined that disputes dealing with the attribution of profits to permanent establishments in India should not be heard by the high court, as the country’s tribunals will have the final say... April 28 2009
This content is from: India Advance ruling allows partnership as a tax planning tool In India, the advance ruling in the case of Canoro Resources addresses the applicability of domestic anti-avoidance provisions to transfers between partners and foreign partnerships. April 28 2009
This content is from: Brazil Substance over form and transfer pricing rules Exports made by a Brazilian company to offshore companies controlled by it, carried out in accordance with Brazilian transfer pricing rules, are analysed from a substance over form approach and regarded as sham transa... April 28 2009
This content is from: Canada Chrysler settles part of tax nightmare Car maker Chrysler is closer to a strategic alliance deal with Fiat SpA after eliminating a transfer pricing hurdle that had threatened the process. April 28 2009
This content is from: Austria Intercompany loan interest rate addressed in Austria The Austrian Ministry of Finance discussed the appropriate interest rate when a group financing entity is located in a foreign low tax country in its annual tax meeting, meaning potential changes for taxpayers. April 27 2009
This content is from: United Kingdom Retailer breaches UK transfer pricing law A UK company has been told that it has breached transfer pricing rules, but is unsure just how much it will have to pay HM Revenue and Customs April 22 2009
This content is from: European Union Related company rules simplified in UK budget In a welcome move for multinational companies, the UK chancellor announced he will simplify the corporate gains rules for notional transfers within a group of companies April 22 2009
This content is from: China China transfer pricing filing deadlines changed As if filing returns under the new corporate income tax regime in China was not difficult enough, the authorities have started moving deadlines around, adding more pressure for taxpayers. April 21 2009
This content is from: European Union Charity claims transfer pricing is hurting world’s poorest A UK charity has called on the world’s leaders to target transfer pricing abuses, amid the fear that it is depriving the world’s poorest countries of an estimated $160 billion. April 21 2009
This content is from: United States Clarke Norton and team join DLA Piper US law firm DLA Piper has expanded its transfer pricing practice with the appointment of three new specialists: two principal economists and one of counsel. April 21 2009
This content is from: Argentina Beware the nuances of Latin American rules While many of the countries across the region claim to have rules that follow the OECD guidelines, experts take a different view. April 21 2009
This content is from: Russia Russia to implement new transfer pricing rules by autumn Russia will adopt its long awaited revised transfer pricing legislation later this year, a government representative has said April 14 2009
This content is from: Denmark Denmark punishes Intel for tax avoidance The Danish tax authorities are demanding DKr3.6 billion ($637 million) in back taxes from a multinational company that it claims used aggressive transfer pricing to avoid paying the proper amount of tax April 14 2009
This content is from: Transfer Pricing Rise in Mexican transfer pricing audits expected The new transfer pricing regulations will bring an increase in audit activity, predicts a senior adviser April 12 2009
This content is from: United States Shott gives details on IRS transfer pricing council The US tax authority has established a special transfer pricing council to help coordinate the IRS’ efforts in the area. Barry Shott, [LMSB deputy commissioner (international)], chairs the council and provides more de... April 12 2009
This content is from: China Seminar clarifies taxpayers’ position in China Taxpayers have told China’s State Administration of Tax that they are concerned about how to apply the new transfer pricing regulations during the economic downturn. April 08 2009
This content is from: Ireland Emergency budget improves Ireland’s IP regime Ireland will introduce a tax relief scheme for the acquisition of intellectual property, the country’s finance minster announced yesterday in his supplementary budget speech April 07 2009
This content is from: Egypt Egypt introduces transfer pricing study requirements Egyptian taxpayers with related-party transactions will soon be required to provide a transfer pricing study to support such transactions under planned changes to the country’s tax laws. April 07 2009
This content is from: India Indian tribunal forces drug company to change transaction methods An Indian tax tribunal has ordered a Belgian drug company to rethink its transfer pricing methods for transactions with its Indian subsidiary, despite referring the case back to the transfer pricing officer. April 07 2009
This content is from: United States Ballentine Barbera adds to practice Susan Fickling-Munge and Gerben Weistra have become vice-presidents in Ballentine Barbera/CRA International’s transfer pricing practice April 06 2009
This content is from: China Former NTA official joins KPMG Hiroyuki Takahashi has joined KPMG as a director in the firm’s global transfer pricing services practice. Takahashi will be based in Shanghai. April 05 2009
This content is from: United States KPMG makes a series of additions to the US transfer pricing team KPMG adds three to the firm’s economic and valuation services practice April 05 2009
This content is from: United States IRS forms transfer pricing council The Internal Revenue Service has formed a council to help it deal with transfer pricing matters effectively April 05 2009
This content is from: Brazil Transfer pricing rules for sales of equity stakes It has been discussed whether Brazilian transfer pricing rules apply to the sale of shares and quotas held by Brazilian companies to a related party, as defined by law (including residents in low tax jurisdictions and... April 02 2009
