This content is from: India India’s dispute resolution panel is not mandatory The Indian government has finally confirmed that the country’s new dispute resolution panel is not mandatory, contrary to what taxpayers were led to believe. January 29 2010
This content is from: Canada Canadian APAs grow but so does time for resolving cases The Canada Revenue Agency (CRA) has increased the number of cases accepted in its advance pricing agreement (APA) programme, but the average time for closing cases has also risen. By Erin Kelechava January 28 2010
This content is from: China China closes thin cap loophole China has released a tax circular that closes a loophole in the country’s thin capitalisation rules regarding the deduction of interest payments. January 27 2010
This content is from: United Kingdom UK CFC discussion document well received Taxpayers and advisers believe yesterday’s discussion document on controlled foreign companies reflects a genuine attempt by the UK tax authorities to respond to their concerns. January 27 2010
This content is from: India Global Vantedge case decided in India Hasnain Shroff and Vinita Chakrabarti of KPMG in India look at the Global Vantedge case. January 27 2010
This content is from: Brazil Brazilian transfer pricing rules in turmoil Luiz Felipe Ferraz of Demarest e Almeida in Sao Paulo discusses the nuances of Brazilian tax reforms as an important reform was brought in then quickly reversed in late 2009. January 27 2010
This content is from: Transfer Pricing Revision to the OECD guidelines welcomed The proposed revisions to chapters I-III of the OECD transfer pricing guidelines have been largely welcomed by transfer pricing practitioners, who feel they address more accurately the business environment. January 27 2010
This content is from: United Kingdom UK CFC discussion document will be released tomorrow A document for discussion on the new UK CFC rules will be published by Her Majesty's Treasury and Her Majesty's Revenue and Customs on Tuesday. January 25 2010
This content is from: Transfer Pricing Documentation causes troubles for developing nations How the UN transfer pricing manual should tackle documentation requirements was the subject of a spirited panel on the second day of the meeting of experts. January 21 2010
This content is from: Transfer Pricing Taxpayers come under fire for damaging developing countries Speakers had much to say about the abuse of the tax rules in less sophisticated jurisdictions during a meeting of a UN transfer pricing group meeting this week. January 21 2010
This content is from: Transfer Pricing Dispute resolution is tricky for developing nations Whether existing methods of resolving transfer pricing disputes are suitable for use in developing countries was the subject of an interesting panel at the UN expert group meeting on transfer pricing. January 21 2010
This content is from: Transfer Pricing Country by country reporting sparks controversy A discussion about country by country reporting caused a heated debate at a meeting at the UN this week January 20 2010
This content is from: Ecuador Related-party exemption could open tax planning opportunities In a bid to keep as much money as possible in the local economy as possible, the Ecuadorian government has issued a new reform to tax law, which includes an exemption from the transfer pricing regime for companies tha... January 20 2010
This content is from: Egypt African tax administrators to tackle transfer pricing Tax professionals from across Africa will meet in Cairo in February to discuss transfer pricing issues affecting the continent. By Erin Kelechava January 20 2010
This content is from: Transfer Pricing Enter now for the European Tax Awards 2010 International Tax Review will present its fifth annual European Tax Awards at the Dorchester Hotel in London on May 18 2010 January 20 2010
This content is from: Transfer Pricing The perfect method remains elusive In a frank discussion at a UN meeting of experts, panellists expressed their frustrations about all the available transfer pricing methods. January 19 2010
This content is from: Transfer Pricing UN delegates split on the arm's length standard and apportionment The first panel of a group meeting on transfer pricing at the UN saw a robust argument over the merits of the formulary apportionment method against the arm’s-length principle. January 19 2010
This content is from: Transfer Pricing Developing expertise is crucial Specialists at a UN meeting have stressed the importance of building transfer pricing units within the tax authorities of developing nations. January 19 2010
This content is from: Transfer Pricing Exclusive: UN transfer pricing meeting starts tomorrow TPWeek will be reporting from the first UN meeting focusing on transfer pricing. January 18 2010
This content is from: United Kingdom UK subsidiary settles dispute with HMRC Chemical company Innospec Limited has signed a £3.9 million ($6.5 million) agreement with HMRC in settlement of transfer pricing disagreements. January 18 2010
This content is from: Taiwan Taiwan adjusts withholding tax regime Changes to Taiwan’s tax law mean that gains from structured notes are no longer regarded as interest income and so should be liable for withholding tax. January 18 2010
This content is from: Greece Greek advisers hope for simpler legislation Hopes are high that more straightforward transfer pricing legislation will be enacted as part of the tax reforms expected in March this year. January 14 2010
This content is from: United States New partner at Baker & McKenzie Salim Rahim is now a partner in the Washington, DC office of Baker & McKenzie. January 14 2010
This content is from: United States US Appeals Court withdraws Xilinx opinion In a surprise move the US Court of Appeals for the ninth circuit has withdrawn the opinion and dissent filed on May 27 2009. January 13 2010
This content is from: India Indian safe harbour rules one step closer The introduction of safe harbour rules in India came one step closer this week with the establishment of a committee that will finalise details of the new provision. January 13 2010
This content is from: Australia MAP established between the Isle of Man and Australia A mutual agreement procedure (MAP) for transfer pricing adjustments has been established between the Isle of Man and Australia. January 13 2010
This content is from: Singapore Singapore officially adopts ALP The Singapore government has passed a law that requires taxpayers to comply with the arm’s-length principle. January 13 2010
This content is from: Transfer Pricing KPMG reports strong growth in transfer pricing-related revenue The international professional services firm announced an 11.4% drop in international revenues, but a 5.3% growth in transfer pricing earnings. January 13 2010
This content is from: United States US Appeals Court withdraws Xilinx opinion In a surprise move the US Court of Appeals for the ninth circuit has withdrawn the opinion and dissent filed on May 27 2009. January 13 2010
This content is from: Brazil Controversy over rules and leasing agreements in Brazil The application of the transfer pricing rules in Brazil in relation to leasing agreements executed between related parties in Brazil and abroad is a controversial issue. January 12 2010
This content is from: India Mumbai tribunal rules on applicability of methods to determine ALP In a recent ruling in the case of Gharda Chemicals Limited, interesting questions were raised before the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT), the second appellate and the last fact finding authori... January 12 2010
This content is from: Transfer Pricing Vote now in transactional and planning polls In 2010, International Tax Review is running its third annual online polls of the leading tax transactional and planning advisory firms around the world January 07 2010
This content is from: Canada Crown appeals General Electric decision On January 4 2010, the Crown deposited its notice of appeal with the Federal Court of Appeal to the judgment of the Tax Court of Canada issued on December 4 2009 in the case of General Electric Capital Canada Inc v Th... January 07 2010
This content is from: Transfer Pricing Documentation translation gets make-over A new software product could revolutionise the often lengthy and expensive process of translating transfer pricing documentation. January 07 2010
This content is from: Japan Documentation requirements included in Japanese reform proposals The Japanese government released an outline of its proposal for a 2010 tax reform package on December 22 2009, which is expected to be followed by the 2010 amended tax laws within a few months. January 07 2010
This content is from: United States US extends rules permitting short term loans from foreign subsidiaries The end of the year brought some good news for US taxpayers struggling with liquidity issues after the tax authorities announced they were extending for another taxable year the liberalised rules that permit a foreign... January 07 2010
This content is from: Canada Nortel uses funding agreement to settle IRS claim Bankrupt multinational telecommunications equipment manufacturer, Nortel Networks Corporation, has announced that it has entered into a final Canadian Funding and Settlement Agreement that includes the resolution of a... January 06 2010
This content is from: India Indian tribunal rules on importance of comparable data A recent Indian tribunal ruling has emphasised the importance of using comparable data for the purpose of benchmarking controlled transactions. January 06 2010
This content is from: United Kingdom Google should expect investigation over UK avoidance, says specialist Google, the internet search and software company, should expect an investigation from the UK tax authorities after it used transfer pricing to avoid corporation tax, a leading specialist has said. January 06 2010
This content is from: United States Woodruff leaves KPMG John Woodruff joins Gardere Wynne Sewell as a partner in the tax practice group in the Houston office. January 06 2010
This content is from: India India liberalises foreign technology agreements The Indian government has issued Press Note number 8, modifying the foreign technology agreement/collaboration policy wherein all payments towards royalties, lump-sum fees for transfer of technology and payments for t... January 04 2010
