This content is from: China China expands contemporaneous documentation requirements A regulation released earlier this month by China’s State Administration of Taxation (SAT) makes loss-making single-function enterprises submit transfer pricing contemporaneous documentation to justify their losses. July 28 2009
This content is from: Nigeria Nigerian official asks for transfer pricing compliance Nigerian taxpayers need to make greater efforts to comply with the country’s transfer pricing rules, a leading government official has said. July 28 2009
This content is from: New Zealand Isle of Man’s TIEA contains transfer pricing provision Efforts made by one UK crown dependency to enhance its network of international tax treaties have been bolstered this week by the signing of an agreement that includes transfer pricing provisions. July 28 2009
This content is from: Hong Kong SAR Hong Kong Court of Final Appeal decides on transfer pricing case On July 24 2009, the Hong Kong Court of Final Appeal (CFA) handed down its decision in the Ngai Lik Electronics Company vs CIR case. July 28 2009
This content is from: Transfer Pricing Software has answers to documentation burden Businesses are paying for less external advice as they try to save money during the economic downturn. Some have turned to software to help with transfer pricing documentation. July 27 2009
This content is from: Australia Australian Customs produces guidance on valuation and transfer pricing The Australian Customs authorities have released guidance detailing how taxpayers should apply for a valuation advice relating to transfer pricing. July 22 2009
This content is from: Netherlands Proposals to change interest deductibility may affect intercompany loans A proposal from the Netherlands government makes it even more important for companies to have sufficient documentation in place to support the arm’s-length nature of inter-company financial transactions between Dutch ... July 21 2009
This content is from: United Kingdom Transfer pricing study targets football clubs Transfer pricing theory has long been associated with transactions within multinational companies, but now it is being applied to the exchange of football players between English football [soccer] clubs. July 21 2009
This content is from: Transfer Pricing Stronger transfer pricing regimes needed, warns IMF Governments should strengthen transfer pricing regulations and enact a general anti-avoidance rule to address cross-border-compliance risks in the recession, an IMF report has said July 20 2009
This content is from: Germany Business restructuring troubles taxpayers in Germany Werner Stuffer and Jörg Hanken of PricewaterhouseCoopers discuss German business restructuring regulations and how the economic crisis affects this area of tax planning. July 20 2009
This content is from: Sweden Swedish court confirms arm’s-length principle for intercompany loans The Swedish Administrative Court of Appeal has upheld a lower court decision clarifying the determination of the arm’s-length interest rate for intercompany loans in a case involving one of the country’s largest real ... July 14 2009
This content is from: China China concludes first bilateral APA with European country The milestone arrangement between China and Denmark is also the first bilateral advance pricing arrangement (BAPA) to be signed since the country’s new transfer pricing regulations were released in January 2009. July 14 2009
This content is from: Russia Russian transfer pricing changes will boost revenues Russian tax professionals believe the country’s new transfer pricing regulations will bring in mo revenues, amid widespread transfer pricing abuses in the country’s natural resource sector. July 14 2009
This content is from: India India Budget offers safe harbour as fast track solution to disputes Vineet Chhabra and Viswanathan Subramaniam of Deloitte India discuss the key budget amendments in the transfer pricing regulations and its implications on the taxpayers and the revenue authorities July 13 2009
This content is from: United Kingdom UK proposes new capital gains rules for groups The UK government is asking for public opinion on new capital gains rules for groups of companies. July 07 2009
This content is from: Germany TPDoctor: German transfer of functions legislation A Polish contract manufacturer for Plastic AG, a German entrepreneur, delivers the final goods directly to a customer. Now Polish SA takes over and invoices the customer. Does this trigger any German taxes? July 07 2009
This content is from: Italy Circular puts Italian tax police on related-party alert The general headquarters of the Italian Tax Police have issued a circular letter aimed at providing tax officers with updated instructions on the assessment activities they should perform. July 07 2009
This content is from: India India tackles transfer pricing disputes After eight years of continuous controversy and adjustments, India’s government has outlined a reform package that aims to reduce the number of transfer pricing disputes in the country. July 07 2009
This content is from: Transfer Pricing Global Transfer Pricing Forum is centre of debate Transfer pricing has never been under so much scrutiny from taxpayers and tax authorities. Profits and, consequently, tax receipts are dwindling, as the recession in the global economy has put company balance sheets a... July 06 2009
This content is from: India Indian budget makes key changes to transfer pricing provisions Hardev Singh and Saurabh Dhanuka of KPMG highlight the key changes the Indian Union Budget 2009 makes to the transfer pricing and related provisions of the Income-tax Act, 1961 July 05 2009
This content is from: India Revenue authorities struggle to alter method applied A ruling by the Pune tribunal says that the revenue authorities in India must clearly demonstrate the appropriateness of a particular method when trying to make an adjustment based on the taxpayer's method choice. Vin... July 01 2009
This content is from: South Africa TPA moves into Turkey and South Africa Transfer Pricing Associates, an independent provider of global transfer pricing and valuation services, is establishing operations in two new jurisdictions. July 01 2009