This content is from: China Rules develop rapidly in Asia Pacific More and more countries in the Asia Pacific region are installing transfer pricing documentation requirements and methods of dispute resolution report Steven Tseng, Yasuhiko Otani, and Hiroyuki Takahashi, from KPMG in... September 30 2009
This content is from: Transfer Pricing Transfer pricing awards winners revealed At International Tax Review’s fourth annual Americas Tax Awards held in New York on September 30, awards were presented for transfer pricing in 14 countries and cities. There were also a regional award each for Latin ... September 30 2009
This content is from: Thailand Thailand: Authorities put taxpayers on their guard The growing interest of the tax authorities in transfer pricing has increased taxpayers' recognition of the importance of transfer pricing risk assessment and management in Thailand, says Benjamas Kullakattimas of KPMG September 30 2009
This content is from: China 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 September 30 2009
This content is from: Sponsored Transfer of intellectual property by South African residents In terms of the rulings issued by the South African Reserve Bank it is not possible to transfer intellectual property(IP) from South Africa to a non-resident without the prior approval of the South African Reserve Bank. By ITR Correspondent September 30 2009
This content is from: Transfer Pricing MAPs on the rise in OECD countries The number of completed mutual agreement procedures is increasing among OECD countries, new statistics have revealed September 30 2009
This content is from: Transfer Pricing OECD releases new transfer pricing guidelines September 30 2009
This content is from: Venezuela Audits in Venezuela top $40 million The Venezuelan tax administration (SENIAT) is continuing a transfer pricing audit campaign for fiscal years 2005 to 2008 September 30 2009
This content is from: Brazil Transfer pricing and packaging of products A recent decision of the Taxpayers Council about the resale price less profit methods described by Brazilian transfer pricing rules has led to debate about the use of such methods for controlling import prices of good... September 30 2009
This content is from: Hong Kong SAR The evolving transfer pricing landscape in Hong Kong Enforcement and regulatory developments mean that transfer pricing framework in Hong Kong is changing, believe Kari Pahlman, Nathan Richards and Justin Kyte of KPMG in China September 30 2009
This content is from: India India: Get ready to take advantage of green agenda Companies should be aware of what the transfer pricing requirements and opportunities are when following a green agenda, explain Shyamal Mukherjee, Sanjay Tolia, Bipin Pawar and Arun Saripalli of PricewaterhouseCoopers September 30 2009
This content is from: Germany German legislation for the relocation of functions explained Alexander Voegele and Hendrik Fuegemann of NERA Economic Consulting outline how new administrative guidelines are affecting taxpayers’ application of the relocation of functions regulations in Germany September 30 2009
This content is from: United States Taxpayers face service deduction problems Service transactions are the source of numerous transfer pricing disagreements between taxpayers and tax authorities, a panel of transfer pricing experts has said September 30 2009
This content is from: South Korea South Korea: Transfer pricing and customs should come together Dong Soo Kim, Duk Won Suh and Joseph Hong of Yulchon discuss how transfer pricing and customs valuation could be harmonised to reduce the burden on taxpayers September 30 2009
This content is from: Philippines Philippines: Taxpayers wait for approval of transfer pricing rules When the Philippines' rules come into effect they will follow the OECD guidelines. Companies have been waiting for them for more than three years, explains Maria Peralta of KPMG September 30 2009
This content is from: Japan Japan: Officials keep up transfer pricing heat on taxpayers Over the last year, there have been significant transfer pricing developments in Japan, among them several changes to the regulations as well as a major court ruling, explains Karl Gruendel, Ernst & Young Shinnihon Tax September 30 2009
This content is from: Singapore Singapore: Authorities expand on transfer pricing guidance The Inland Revenue authority of Singapore has explained more about how it supports the arm's length, principle report, Geoffrey Soh, Iwan Hoo and Ziad Rahman from KPMG in Singapore September 30 2009
This content is from: India Threat of court will benefit taxpayers The threat of taking a transfer pricing dispute to court is a good bargaining tool for taxpayers in developing countries, a panel of transfer pricing specialists has said September 28 2009
This content is from: Australia Transfer pricing structures come under pressure Companies are changing their transfer pricing structures to deal with the global economic downturn, both to accommodate changes in the business situation and adapting to extra pressure from tax authorities. September 23 2009
This content is from: United States Ernick calls for continued cooperation Taxpayers and tax authorities must work together to prevent transfer pricing becoming a barrier to international trade, a leading US Treasury official has said September 23 2009
This content is from: United States Tax audits and controversies increasing The economic crisis means tax authorities are conducting more audits to boost revenues. More companies are challenging adjustments, leading to a rise in controversy September 23 2009
This content is from: Germany German transfer pricing rules under fire The field of tax treaties develops at a rapid pace. Discussions relating to business restructuring are one factor affecting the transfer pricing issues for international treaties. September 23 2009
This content is from: Netherlands Taxpayers must give more information to auditors Companies must be prepared to divulge more information for transfer pricing audits than in other similar situations, said panellists at the Global Transfer Pricing Forum September 22 2009
This content is from: France French Ministry explains documentation details More information has been released on France’s new transfer pricing documentation requirements September 22 2009
This content is from: France Arbitration process causes problems for French taxpayers The complex procedure and uncertainty of the arbitration system in France led to some heated debate at the Global Transfer Pricing Forum September 22 2009
This content is from: Transfer Pricing OECD reaffirms arm’s length’s future The future of the arm’s-length principle looks certain, as there is no viable alternative available, the head of the OECD's transfer pricing unit has said September 22 2009
This content is from: France Intangibles could be on OECD agenda The head of the OECD's transfer pricing unit told a conference in Paris today that she and her colleagues were discussing whether a project on intangibles should be part of the next work programme of the organisation'... September 21 2009
This content is from: China China’s newest documentation challenge: how to defend loss-makers Loss-making documentation is a catch-22 situation in China. Glenn DeSouza, managing director at Transfer Pricing Management Consulting in Shanghai, which has an exclusive strategic alliance with Baker & McKenzie, expl... September 16 2009
This content is from: European Union Practitioners welcome plans to revise arbitration code of conduct The European Commission has proposed a revision of the code of conduct for applying the arbitration convention (AC) in a bid to strengthen the measure that acts to prevent double taxation in transfer pricing cases in ... September 16 2009
This content is from: United States New nominee for top US tax policy role announced President Barack Obama has revealed Michael Mundaca as his nominee for assistant secretary for tax policy, department of the Treasury. September 16 2009
This content is from: China SAT holds training session on pharmaceutical industry The Chinese State Administration of Taxation (SAT) hosted an important national training session focused on the pharmaceutical industry for over 100 transfer pricing officials across the country this week September 16 2009
This content is from: Germany TP Doctor: Administrative services in tax audits and German formal requirements If a German affiliate of a MNE receives administrative services (for example tax, legal and accounting advice) from a foreign holding corporation what formal requirements must be met under German rules? And how do th... September 15 2009
This content is from: India India’s dispute panel proves popular choice India’s new dispute resolution panel is proving to be a popular choice with the country’s highest court, though the mechanism does not become effective for another two weeks By Jack Grocott September 15 2009
This content is from: Transfer Pricing OECD releases new transfer pricing proposals The OECD has released a proposed revision of several important chapters of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations September 13 2009
This content is from: France Arbitration under fire in France The lengthy process involved in arbitration matters, sometimes taking up to six years to reach a resolution needs to be changed, says a leading adviser. September 08 2009
This content is from: United States Tax authorities improve at tackling transfer pricing International businesses need to take a more assertive, proactive approach to implementing and managing their transfer pricing policies, a report has said September 08 2009
This content is from: Malaysia Malaysia set to increase audit activity The number of transfer pricing audits in Malaysia is set to increase as the country’s tax authority attempts to improve taxpayer compliance By Jack Grocott September 08 2009
This content is from: China China identifies audit targets China’s State Administration of Taxation (SAT) has issued a circular that identifies transfer pricing audit targets and specifically provides directives relating to special inspections of non-resident enterprises September 08 2009
This content is from: India Thin capitalisation is on the way to India India’s proposed new direct taxes code has provisions in the fine print that propose the introduction of thin-capitalisation rules September 07 2009
This content is from: United States IRS hits taxpayer with $3 billion claim The US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties September 07 2009
This content is from: Australia Entries close for Asia Awards on September 7 Transfer pricing will feature strongly when International Tax Review presents its third annual Asia Tax Awards in Singapore on November 24 September 01 2009
This content is from: Venezuela Venezuela hits US taxpayers with multi-million dollar adjustments The Venezuelan tax authorities have stepped up their attempts to generate extra tax revenue by targeting the transfer pricing methodologies of large automotive and pharmaceutical companies September 01 2009
