This content is from: Chile Good news for taxpayers as Chile joins OECD Taxpayers should be pleased with the news that Chile is joining the OECD as the country will benefit from a clearer set of transfer pricing rules, says a leading Chilean tax professional. December 18 2009
This content is from: Transfer Pricing Transfer pricing gets more contentious Tax authorities across the world are increasing their transfer pricing resources, issuing more penalties and preparing for a greater number of disputes, says a report by a leading tax advisory firm. December 18 2009
This content is from: Brazil Brazil introduces thin capitalisation rules Brazil has unveiled legislation that contains the country’s first thin-capitalisation rules. December 18 2009
This content is from: Australia Australia proposes thin capitalisation changes The Australian government has released for public consultation draft legislation on proposed changes to the country’s thin capitalisation rules. December 18 2009
This content is from: United States Taxpayers victorious in cost sharing buy-in payments case Paul Flignor, Alan Granwell and Eric Ryan of DLA Piper discuss the landmark Veritas decision and the implications for taxpayers December 18 2009
This content is from: Transfer Pricing Update: UN transfer pricing meeting set for January The UN tax committee will discuss drafting guidelines on transfer pricing at a meeting scheduled for January 19 and 20 in New York. December 18 2009
This content is from: Canada GE Capital verdict leaves room for doubt The GE Capital case has left market commentators encouraged but in doubt about what the judgement really means for the arm’s-length principle in Canada. December 16 2009
This content is from: Chile Chile steps up audit programme Ricardo Escobar, the chief of the Chilean tax authority (Servicio de Impuestos Internos or SII), says the SII has detected “certain abusive behaviours from the Chilean taxpayers”. December 16 2009
This content is from: Netherlands Dutch minister proposes radical permanent establishment changes The Dutch deputy minister of finance has proposed a new law that would make losses from permanent establishments no longer deductible from a company’s worldwide profit. December 16 2009
This content is from: Uruguay Uruguay updates regulations The Uruguayan General Tax Bureau has released a resolution that provides further details on the country’s transfer pricing regime, three months after new regulations were released. December 16 2009
This content is from: United States Inadequate controls is a tax risk not worth taking Charlene Unitan, formerly with Rolls-Royce and now with boutique firm UNITAX, warns companies to be aware of their tax risks and keep transfer pricing in check. December 16 2009
This content is from: United States Court slates IRS approach in Veritas litigation In a landmark decision, the US Tax Court has addressed the fundamental issues in the valuation of cost-sharing buy-ins and slammed the approach of the Internal Revenue Service (IRS) to the case. December 16 2009
This content is from: United States New transfer pricing boutique established Charlene Unitan has set up a transfer pricing boutique called UNITAX. December 15 2009
This content is from: Hong Kong SAR Guidance gets mixed reviews from Hong Kong taxpayers The release of Hong Kong’s newest practice note on transfer pricing has been widely welcomed by taxpayers, but concerns have been raised over its lack of clarity. December 10 2009
This content is from: India Indian authority rules on transfer pricing provisions In a recent ruling, the AAR (Authority for Advance Rulings) in India held that transfer pricing provisions are only computational provisions and in the absence of charge of tax under any particular head of income spec... December 10 2009
This content is from: India India sends officials to Mauritius and Singapore The Indian tax authority has sent two senior tax officials to Mauritius and Singapore to ensure that tax treaty arrangements are being maintained. December 10 2009
This content is from: Indonesia Indonesia steps up scrutiny of related-party transactions The Indonesian Tax Office (ITO or DGT) is proactively approaching taxpayers and requiring them to answer queries and questionnaires. December 10 2009
This content is from: Canada Canadian court shakes up arm's-length principle On December 4 2009, the long awaited decision in General Electric Capital Canada Inc v The Queen was released by Canada's Tax Court. December 09 2009
This content is from: Belgium Draft law provides for tax haven reporting Recently new draft tax law provisions have been filed with the Belgian Parliament (Parl St, Kamer, 2009-2010, nr 52-2278/001) for further discussion. December 07 2009
This content is from: United Kingdom Another law firm hires transfer pricing specialist Cameron McKenna has continued the trend of law firms hiring transfer pricing expertise. December 07 2009
This content is from: Hong Kong SAR Hong Kong produces practice note On Friday, the Hong Kong Inland Revenue Department (IRD) released Departmental Interpretation a Practice Note (DIPN) 46, establishing the tax authority’s interpretation and practices on transfer pricing methodologies ... December 07 2009
This content is from: Transfer Pricing Updated - Pharma companies face challenges with transfer pricing programmes A report says that transfer pricing practices in the pharmaceutical industry will become more complex due to the economic and political pressures that companies in the sector are facing December 03 2009
This content is from: Kenya Multinationals targeted as Africa promotes transfer pricing Multinational taxpayers in Africa will have to start developing their transfer pricing policies and documentation to deal with the increasing number of countries in the region putting guidelines in place or reforming ... December 02 2009
This content is from: Indonesia Indonesia could change coal pricing policy The Indonesian government could reverse a key plank of its coal policy that was put in place to deal with transfer pricing abuses. December 02 2009
This content is from: India India’s dispute panels cause confusion India’s new dispute resolution mechanism has not got off to a good start. December 02 2009
This content is from: Argentina South American taxpayers face more audits in 2010 Taxpayers in South America should expect greater scrutiny from the transfer pricing authorities in 2010, says a leading adviser. December 02 2009
This content is from: United States Transfer pricing rises up the scale for Bric Increased foreign investment and regulation are just two of the reasons why the Bric countries have become significant locations for transfer pricing, points-out Shiv Mahalingham of Alvarez & Marsal Taxand UK December 01 2009
This content is from: Germany Transfer pricing surfaces in new coalition agreement Germany's new government asserts to scrap harmful effects of the transfer of functions legislation, explain Lorenz Bernhardt and Ludger Wellens of PricewaterhouseCoopers December 01 2009
This content is from: France New rules on transfer pricing documentation and on tax avoidance December 01 2009
