This content is from: Coping with the economic downturn A key lesson of the global volume recession in 2008 and 2009 is that transfer pricing benchmarking and comparability studies need to be revised to take account of changing economic conditions, explain Seen Meng Chew a... April 30 2010
This content is from: Philippines Philippines establishes taskforce to target mulitnationals The Philippines Bureau of Internal Revenue has established a special team to investigate the transfer pricing activity of multinationals operating within the country. April 29 2010
This content is from: Brazil How to change fixed profit margins in Brazil Andréa de Oliveira Ramos and Cristiane Magalhães of Machado Associados in Brazil discuss the important idea of changing fixed profit margins that are used to calculate benchmarks in the country. April 25 2010
This content is from: China China asks for translation of OECD report China has shown that it is taking a close interest in transfer pricing developments outside its borders by commissioning a translation of an influential international report. April 25 2010
This content is from: India Mumbai Tribunal rules on important arm's-length case Hasnain Shroff and Vinita Chakrabarti report on an interesting case, where it was held that in order to determine the arm’s-length price of an international transaction, the arm’s-length margin should be applied only ... April 25 2010
This content is from: Transfer Pricing Under-development of financial markets causing problems Hernán Katz of Deloitte in Mexico describes how many transfer pricing difficulties faced by taxpayers in Latin America are linked to the lack of development in the regions’ financial markets. April 25 2010
This content is from: Australia Taxpayers struggle to respond to Australian information demands The Australian Taxation Office (ATO) sent out about 140 transfer pricing questionnaires in the first two months of this year as part of its Strategic Compliance Initiative (SCI), but taxpayers have complained the ques... April 20 2010
This content is from: United States US company releases $12 million in income tax reserves Relying on the March 22 2010 decision in the Xilinx litigation case, Altera Corporation, a leader in reprogrammable logic devices, is confident it will not face the level of corporate tax it was expecting. April 20 2010
This content is from: South Africa Exclusive: South African authorities plan to add more resources Franz Tomasek, head of legislative research and development for the South African Revenue Service (SARS), explains how companies are selected for audit and reveals the many possible methods for dispute resolution avai... April 20 2010
This content is from: Japan Japanese multinational prepares for significant adjustment Toray Industries, a leading Japanese chemical manufacturer, has revealed it expects to receive a notice of correction based on transfer pricing issues raised by the Tokyo Regional Taxation Bureau. April 20 2010
This content is from: Canada NERA Economic Consulting hires one and promotes another Jennifer Shulman has joined the economic advisory and analysis firm as a vice president in its global transfer pricing practice, based in the US, while Makoto Ikeya was promoted to vice president in the Tokyo office. April 15 2010
This content is from: Japan Japan’s rocky road to transfer pricing documentation Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo comment on increasing documentation burdens for taxpayers in Japan. April 15 2010
This content is from: Denmark Large increase in transfer pricing audits in Denmark The Danish tax authorities have collected DKK 15 billion ($2.8 billion) from transfer pricing audits of 32 multinational companies. April 14 2010
This content is from: United States Aaron Bone joins Charles River Associates CRA hires senior manager from Ernst & Young. April 14 2010
This content is from: Transfer Pricing Country-by-country reporting gathers steam A controversial system of global profit reporting is gaining support as the European Commission is asked to examine how country-by-country reporting could become the norm in Europe. April 13 2010
This content is from: China Transfer pricing in Hong Kong is changing post DIPN 46 Jacqueline Shek and Dawn Quek of Baker & McKenzie Hong Kong and Glenn DeSouza of TP Management Consulting in Shanghai evaluate some of the unusual aspects of departmental interpretation and practice note number 46 and... April 13 2010
This content is from: Transfer Pricing Designing a dynamic global transfer pricing policy Batanayi Katongera of Olswang explores the practicalities of designing and implementing a dynamic global transfer pricing policy document. April 13 2010
This content is from: United Kingdom Report blasts charity’s transfer pricing link to child mortality A report published by Jersey Finance concludes the data contained in two studies conducted by Christian Aid is flawed. April 13 2010
This content is from: United States Using expected loss to price credit risk: derivatives and factoring Gordon Hands of CUFTanalytics examines two example cases, an interest rate swap and a factoring transaction, where expected loss (EL) is used to price the credit risk portion of the intercompany financial transaction. April 13 2010
This content is from: India Exclusive: India’s top transfer pricing official outlines priorities India’s director-general of international tax and transfer pricing has said thin capitalisation, advance pricing agreements and safe harbour provisions are his three priorities for the coming year. April 12 2010
This content is from: India Indians are keen on new dispute resolution mechanism India’s new dispute resolution panels (DRP) will continually adapt to a changing tax environment and greatly improve taxpayer litigation consistency, say two of the country’s leading advisers. April 12 2010
This content is from: Australia Deloitte adds partner to global group Bill Yohana has joined Deloitte in Australia as a partner in the firm’s global transfer pricing group. April 12 2010
This content is from: South Africa Transfer pricing comes into focus in South Africa Jan-Paul Borman and Amit Chadha of PricewaterhouseCoopers in South Africa discuss how economic pressures and the recent budget have sharpened the tax authorities’ attentions on transfer pricing. April 11 2010
This content is from: Russia Taxpayers must prepare for new rules in Russia Maxim Alekseyev, Olga Chugunova and Olga Roslova of ALRUD law firm explain what taxpayers need to be aware of before significant changes are introduced to the transfer pricing rules in Russia. April 11 2010
This content is from: Japan New Japanese rules take effect New transfer pricing rules included in the tax reform package announced by the Japanese Ministry of Finance in December finally came into effect on April 1. April 06 2010
This content is from: United Kingdom HMRC issues new guidance on thin capitalisation In March 2010 HM Revenue & Customs (HMRC) released an update of the guidance in its International Manual on the UK’s thin capitalisation rules. This guidance is prepared primarily to assist inspectors of taxes in app... April 06 2010
This content is from: Poland Poland targets transfer pricing audits in 2010 Polish taxpayers have been sent a strong warning after the country’s tax authorities confirmed that they will focus their 2010 audit work on transfer pricing and its associated issues. April 06 2010
This content is from: United States Comments deadline extended on US disclosure requirement proposal The deadline for interested parties to submit comments on the new disclosure requirement that would affect many US companies with international dealings has been extended until June 1 2010. April 06 2010
This content is from: Transfer Pricing OECD and the Council of Europe agree on update to treaty It is hoped the new protocol will boost multilateral cooperation and reduce cross border tax evasion. April 05 2010
This content is from: Spain Survey finds large rise in controversy in Spain A survey by accounting firm KPMG found 82% of respondents said they faced the same level of transfer pricing controversy as last year. In Spain there was a significant increase, however. April 05 2010
This content is from: China Circular clarifies Chinese tax law The State Administration of Taxation (SAT) in China has issued a circular that further clarifies certain aspects of the country’s tax law. April 05 2010
This content is from: India Advance Ruling Authority clears up applicability of India-Mauritius treaty Sanjay Sanghvi and Daksha Baxi discuss the landmark E*TRADE litigation and its implications for the India-Mauritius tax treaty. April 05 2010
