This content is from: Transfer Pricing OECD releases draft on permanent establishments The OECD has released a revised discussion draft for a new article seven of its model tax convention, which relates to permanent establishments November 26 2009
This content is from: Brazil Questions raised over Brazil’s transfer pricing rules Twelve years after Brazil introduced transfer pricing laws and enacted the arm’s-length standard, Luiz Felipe Ferraz and Alexandre de S Almeida of Demarest e Almeida Advogados in Brazil assess whether the standard is ... November 26 2009
This content is from: Netherlands Documentation will be key to Dutch innovation box Recent tax changes announced in the Netherlands budget will not affect transfer pricing, but intangibles have become a target for tax authorities November 26 2009
This content is from: Australia KPMG wins for transfer pricing in Asia KPMG took the top award for transfer pricing at International Tax Review’s Asia Tax Awards in Singapore last Tuesday November 26 2009
This content is from: Australia Australia hires 60 officials to scrutinise large taxpayers The Australian Tax Office has hired 60 transfer pricing specialists to clamp down on abuses undertaken by large taxpayers. November 25 2009
This content is from: India India releases dispute panel rules The Indian Central Board of Direct Taxes (CBDT) has finally unveiled rules for the country’s new dispute resolution panels (DRP), nearly two months after the mechanism became effective. Samir Gandhi and Vineet Chhabra... November 25 2009
This content is from: Brazil Transfer pricing hinders treaty negotiations in Latin America Nonconforming transfer pricing rules in some Latin American countries are leading to problems with tax treaty negotiations November 23 2009
This content is from: India Indian safe harbour rules are a “double-edged sword” The introduction of safe harbour rules to India is a “double-edged sword” and the tax authorities need to be careful with how they implement them, says a report. November 19 2009
This content is from: China Transfer pricing audits becoming more focused in China Loss making companies, those with strange profit patterns or with a large amount of related party transactions are the key targets of audits in China, according to leading advisers. November 19 2009
This content is from: Transfer Pricing UN to draft transfer pricing guidelines The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 2010. November 19 2009
This content is from: European Union High Court rules in favour of taxpayers in thin cap GLO case The test claimants in the UK thin-capitalisation group litigation against HM Revenue & Customs have won their challenge in the High Court in London that the rules infringed the freedom of establishment article of the ... November 19 2009
This content is from: India Patel leaves ELP Vispi Patel has left his role as head of direct tax at Economic Laws Practice in Mumbai November 18 2009
This content is from: Netherlands True Partners Consulting expands True Partners Consulting International network, an association of tax consulting firms in select markets around the world, has added three new affiliates. November 17 2009
This content is from: Taiwan Phoenix Technologies reaches settlement with Taiwan authorities Deal reduces the technology company’s tax bill for the fiscal years 2000 to 2006 by $5.2 million. November 17 2009
This content is from: United Kingdom The future of comparables in transfer pricing Wendy Nicholls and Leela Murugasu of Grant Thornton investigate how deep taxpayers must dive to find suitable comparables today. November 17 2009
This content is from: China Companies urged to meet deadline for documentation Companies operating in China have until December 31 to prepare comprehensive transfer pricing documentation. November 17 2009
This content is from: Transfer Pricing OECD releases MAP statistics The OECD has released statistics on the mutual agreement procedure (MAP) caseloads of all member countries for the period of 2006 to 2007. November 11 2009
This content is from: Transfer Pricing Report warns taxpayers about transfer pricing policies Multinational companies need to adjust their transfer pricing systems rapidly to stave off the revenue-hungry tax authorities, says a report. November 11 2009
This content is from: Spain Spanish firm adds to partnership Garrigues has appointed three new international tax and transfer pricing partners. November 11 2009
This content is from: Russia Russia’s new transfer pricing law submitted to government Russia’s long-awaited new transfer pricing law has been submitted to the government and could be implemented in July next year. November 11 2009
This content is from: Brazil Brazil steps up scrutiny of service transactions The Brazilian government is introducing a new system of reporting imports and exports relating to cross-border transactions involving services and intangibles. November 11 2009
This content is from: Canada Climate change and transfer pricing Demet Tepe and Ken Kyriacou of Ernst & Young in Canada explain how companies must be aware of the effect making changes to the business to accommodate climate change initiatives can have on transfer pricing policies. November 09 2009
This content is from: United Kingdom Peters puts his name above the door The former managing partner of KPMG's global transfer pricing services practice has established his own firm November 06 2009
This content is from: United States TPDoctor: How will new US legislation affect transfer pricing? When considering the current tax legislative agenda, what implications can we expect for transfer pricing? November 04 2009
This content is from: Transfer Pricing Oman awaits extra information on new rules Five months after the Sultanate of Oman released information on the country’s first ever set of transfer pricing rules, little is still known about what they cover. November 04 2009
This content is from: Chile TPA expands strategic alliances Transfer Pricing Associates signed three more strategic alliance agreements last week, bringing the total of similar link-ups to six during October November 04 2009
This content is from: India Indian court says assessing officer cannot make further adjustments Samir Gandhi and Manisha Gupta of Deloitte India explain the importance of recent controversy for taxpayers dealing with issues involving section 40A of the 1961 Income Tax Act. November 04 2009
This content is from: China China’s new transfer pricing rules: the first 200 days Spencer Chong, Cecilia Lee, Charles Chan and Paul Tang of PricewaterhouseCoopers describe how the situation for taxpayers has changed since the overhaul of the China’s transfer pricing rules. November 04 2009
This content is from: China China concludes first European bilateral APA The Chinese tax authorities have concluded their first bilateral advance pricing arrangement (BAPA) with a European country November 04 2009
This content is from: Canada Canadian MAPs rise and take longer to settle In its annual report on its mutual agreement procedure (MAP) programme, the Canada Revenue Agency (CRA) notes an increase in both the number of cases brought and also the time taken to resolve the matters. November 04 2009
This content is from: United States Select practitioners turn out for awards New York was the place to be for another successful evening at International Tax Review's America Tax Awards November 01 2009
