This content is from: United States IFRS will affect cost sharing arrangements Vu Tran and Alexander Gurevich of PricewaterhouseCoopers in the US discuss how the change from US GAAP to IFRS will affect cost sharing arrangements June 30 2009
This content is from: Malaysia Rules needed to clarify transfer pricing landscape Transfer pricing rules are on the way in Malaysia. Until then there is some ambiguity about how existing law applies to related-party transactions, say Anand Raj and Irene Yong of Shearn Delamore & Co June 30 2009
This content is from: Australia ATO given extra funding to combat abuses The Australian Tax Office has been given more government money to tackle aggressive schemes as the onslaught on transfer pricing uses continues in the country. June 30 2009
This content is from: Canada Amendment to Canadian definition of permanent establishment June 30 2009
This content is from: France Tax stars shine at awards The winners of the European Tax Awards picked up their prizes at a dinner in London in May June 30 2009
This content is from: China How changes in transfer pricing will affect taxpayers Steven Tseng and Cheng Chi of KPMG explain what effects new transfer pricing laws, such as detailed documentation requirements, will have on multinationals in China June 30 2009
This content is from: China TPDoctor: Chinese Sanlaiyibu company We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation? June 30 2009
This content is from: Transfer Pricing Taxpayers face difficulties in tackling customs and transfer pricing Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers. June 30 2009
This content is from: United Kingdom Freshfields appoints head of transfer pricing economics Freshfields Bruckhaus Deringer gives Danny Beeton the nod as the firm’s head of transfer pricing economics. June 30 2009
This content is from: Norway Norwegian report attacks transfer mispricing Authors of a report on tax havens and development, commissioned by the Norwegian government, believe international action is required to deal with the problem of transfer mispricing. June 29 2009
This content is from: France France introduces tougher transfer pricing rules Taxpayers in France will be subjected to stricter transfer pricing rules under new legislation. June 29 2009
This content is from: India Tribunal reaffirms the importance of comparability Following a recent Indian tribunal ruling on the use of cash profit/sales, Samir Gandhi and Vineet Chhabra of Deloitte India explain the importance of profit level indicators (PLI) under the TNMM. June 23 2009
This content is from: China SAT answers questions on anti-avoidance administration The latest rules on special tax adjustments were a hot topic when China’s State Administration of Taxation (SAT) held a half-day online question and answer session earlier this month. June 23 2009
This content is from: China China targets highway operations companies The State Administration of Taxation in China has ordered the provincial and local level tax authorities to initiate a nationally coordinated campaign of tax investigations on operators of highways. June 23 2009
This content is from: Canada New report tells governments to abandon arm’s length price Governments should abandon the arm’s-length price and grant multinationals the discretion to set their own transfer prices internally, says a report from the Rotman School of Management at the University of Toronto. June 23 2009
This content is from: Australia ATO set to update APA program The Australian Taxation Office (ATO) has released an external review of the advance pricing arrangement (APA) programme together with an initial response to the recommendations contained in the report. June 22 2009
This content is from: Netherlands Landmark decision in Amsterdam court case on business restructuring The Amsterdam Court of Appeals hands victory to the taxpayer in a transfer of goodwill dispute, limiting the taxes payable. Eduard Sporken, and Jenny Theresia of KPMG discuss the case and its implications. June 22 2009
This content is from: Transfer Pricing TPWeek joins Twitter TPWeek has joined Twitter, the micro-blogging and social networking site, to provide updates on the ever-changing world of transfer pricing. June 22 2009
This content is from: Transfer Pricing Oman issues details on new transfer pricing rules The Sultanate of Oman has finally released details for the country’s first ever set of transfer pricing rules. June 21 2009
This content is from: Transfer Pricing Country-by-country reporting could end transfer pricing misuse For companies that use transfer pricing to avoid paying tax, news that country-by-country reporting is on the agenda of a meeting of G20 finance ministers in Berlin next week is bad news. June 16 2009
This content is from: India How the budget could reform transfer pricing Tarun Arora and Shikha Gupta of PricewaterhouseCoopers outline the problems apparent in the Indian transfer pricing rules and provide suggestions for improving the regulations in the coming budget. June 16 2009
This content is from: Australia D’Ascenzo warns taxpayers against aggressive transfer pricing Michael D’Ascenzo, commissioner of the Australian Tax Office stressed that companies should practice good corporate governance that takes into account tax risks. June 16 2009
This content is from: United Kingdom DSG: a turning point in transfer pricing economics Danny Beeton and Hannah Carter of Grant Thornton in the UK explain how the decision in the DSG case is potentially a turning point in transfer pricing economics, at least in the UK June 16 2009
This content is from: Brazil Authorities use confidential information to ascertain prices Cristiane Magalhães and Fábio Lima da Cunha of Machado Associados in Brazil report on how the authorities have been using information not accessible to taxpayers to determine arm’s-length prices. June 14 2009
This content is from: Transfer Pricing TPDoctor: Mexico annual tax return change What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form? June 14 2009
This content is from: China First unilateral APA signed in Beijing The economic and technological development zone office of the Beijing Municipal State Tax Bureau (BSTB) has signed its first unilateral advanced pricing agreement (APA) after various rounds of negotiations. June 10 2009
This content is from: Transfer Pricing Control over risk commands attention at OECD consultation Control over risk quickly became a significant point of discussion during a two-day public consultation on the transfer pricing aspects of business restructuring at the OECD in Paris this week June 10 2009
This content is from: United Kingdom UK companies on edge after HMRC wins large settlement Following the conclusion of HM Revenue and Customs first major successful transfer pricing dispute, UK taxpayers are being warned that the authorities are thirsty for more. June 09 2009
This content is from: India Taxpayers vote for APAs in India With India’s budget only three weeks away, tax professionals have come out in support of advance pricing agreements as a means of dealing with transfer pricing disputes. June 09 2009
This content is from: Poland Polish business ready to do battle over new scrutiny The Polish ministry of finance has published a document which identifies areas of possible tax fraud to be investigated, with the aim of raising revenues by catching the cheats. One of the priorities is transfer of in... June 09 2009
This content is from: Canada TPDoctor: Canada Revenue Agency disputes The CRA has a reputation for being aggressive. What is the best way to avoid disputes? Or handle them if they arise? June 09 2009
This content is from: United States Charting the growth of transfer pricing at the IRS Transfer pricing has steadily become one of the number one issues for the Internal Revenue Service (IRS). Alfredo Jay Urquidi of Marsh & McLennan Companies and David Jarczyk of Ceteris discuss. June 08 2009
This content is from: United States Limiting income-shifting through cross-border transfers of intangibles Joe Andrus and Irv Plotkin of PricewaterhouseCoopers explain how President Obama's recent budget may directly affect transfer pricing June 05 2009
This content is from: United States Commissioner Shulman gloats over Xilinx win Speaking of the controversial IRS win in the US Court of Appeals for the Ninth Circuit in the Xilinx case, IRS commissioner Douglas Shulman called the decision a “real victory”. June 03 2009
This content is from: India Group calls for Indian transfer pricing changes A leading Indian business lobby group has asked the government to rethink transfer pricing rules and to create a uniform approach for information technology businesses. June 03 2009
This content is from: Taiwan TPDoctor: Taiwan documentation What documentation do I need to prepare and file by what time for entities in Taiwan? June 03 2009
This content is from: Transfer Pricing Oman set for transfer pricing Oman is set to introduce transfer pricing rules in an effort to attract further investment to the country June 02 2009
This content is from: Hong Kong SAR Hong Kong issues guidance but risks remain The Hong Kong Inland Revenue Department has released a highly anticipated guidance document on transfer pricing and profit allocation. Travis Benjamin and Glenn DeSouza of Baker & McKenzie discuss the development. June 02 2009
