Transfer Pricing

Archive: Transfer Pricing

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Australian judge sets aside OECD guidelines

An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
June 30 2010
This content is from: United States

Miller & Chevalier hires Robert Kirschenbaum

Robert Kirschenbaum has moved from Baker & McKenzie to join Miller & Chevalier Chartered in Washington, DC.
June 30 2010
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Ease-up on transfer of functions
June 30 2010
This content is from: Australia

Australian judge sets aside OECD guidelines

An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
June 29 2010
This content is from: Brazil

Non-conversion of executive measure into law causes problems in Brazil

Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil.
June 29 2010
This content is from: United States

Patton leaves Ernst & Young

After 21 years with Ernst & Young, Mike Patton is leaving the firm to join DLA Piper.
June 29 2010
This content is from: Pakistan

Pakistan accuses pharmaceutical companies of malpractice

The Federal Board of Revenue (FBR) in Pakistan believes pharmaceutical companies have used transfer pricing to evade Rp500 million ($5.8 million) in taxes.
June 29 2010
This content is from: Canada

Blakes hires two litigators

Canadian law firm Blake Cassels & Graydon has taken two tax litigators from rival McCarthy Tétrault.
June 28 2010
This content is from: United States

Pendo Advisors adds a valuation specialist

Pendo Advisors, a corporate finance and valuation advisory firm in Chicago, has announced the addition of Dan Bourgeois, who has a tax and transfer pricing background, as a managing director
June 28 2010
This content is from: United States

Establishing nexus for state and local taxation in the US

Bruce Clements of Kennesaw State University discusses the dangerous area of establishing an economic connection with States in the second of a three-part discussion of state and local considerations in US business pla...
June 27 2010
This content is from: United States

FEI gives APA process a glowing report

The conclusion of a bilateral advance pricing agreement (APA) between the US and the Netherlands will allow FEI, a scientific instruments company, to release large valuation allowance and tax reserves from its account...
June 27 2010
This content is from: Australia

Australia reforms thin capitalisation rules

The Australian parliament has finally passed reforms to the country’s thin capitalisation rules.
June 27 2010
This content is from: China

China targets automotive industry

Chinese taxpayers are being urged to revisit their transfer pricing policies after the tax authorities announced that it is increasing its scrutiny of the country’s automotive industry.
June 22 2010
This content is from: United Kingdom

UK budget contains some transfer pricing surprises

The UK coalition government’s first budget contained some provisions that will interest transfer pricing practitioners and cause alarm among the financial industry in particular. It also raised the prospect of a gener...
June 22 2010
This content is from: Canada

Ex-Canada Revenue Agency official talks to TPWeek

Fred O’Riordan, formerly with the CRA, talks about moving into the private sector and reveals his hopes for the future of arbitration between the US and Canada.
June 22 2010
This content is from: Italy

Italian taxpayers welcome clearer guidelines

Transfer pricing documentation requirements introduced under Law decree number 78 will provide clearer guidance for Italian taxpayers.
June 22 2010
This content is from: India

Indian advisers anxious about transfer pricing under the DTC

The Indian government has released a revised discussion paper on the controversial Direct Tax Code (DTC) containing several provisions that will affect transfer pricing.
June 22 2010
This content is from: Uruguay

Taxpayers given longer to pay tax in Uruguay

The General Tax Bureau (GTB) in Uruguay has extended the deadline for corporate income tax (CIT) payments due after the application of the transfer pricing regime and provided additional guidelines about related parti...
June 21 2010
This content is from: Netherlands

Dutch APAs and ATRs dropped in 2009

Eduard Sporken and Neil Schaatsbergen provide background information on APAs/ATRs in the Netherlands and comment on the related statistics recently published by the Dutch tax authorities.
June 21 2010
This content is from: India

Courts provide relief to Indian taxpayers over penalties

Samir Gandhi, Manisha Gupta and Radhi Raman of Deloitte in India discuss the overzealous use of penalty provisions in the country.
June 15 2010
This content is from: China

Asian countries top aggressive tax authority poll

China and India have leapt up the table to join Japan at the top of the latest TPWeek poll to find the most aggressive transfer pricing officials in the world.
June 15 2010
This content is from: Brazil

New additions to the Brazilian blacklist of privileged tax regimes

The Brazilian government has added 14 new jurisdictions to their blacklist of privileged tax regimes.
June 15 2010
This content is from: Poland

Polish transfer pricing rules torment taxpayers

Companies operating in Poland are being forced to remain vigilant to avoid falling foul of the country’s strict transfer pricing rules which require documentation submitted in Polish within seven days of request.
June 15 2010
This content is from: Ecuador

Secret comparables authorised in new Ecuadorian law

Alexis Carrera of Ernst & Young in Ecuador explains that the Ecuadorian tax administration seems to be straying further from transfer pricing best practices and the OECD guidelines.
June 14 2010
This content is from: Ireland

Irish tax authorities release documentation guidelines

In Tax Briefing Issue 07 of 2010, released on June 10, the Irish tax authorities have issued guidance on the documentation that is required from taxpayers to comply with the new transfer pricing rules.
June 14 2010
This content is from: Brazil

Machado Associados hires former government head of transfer pricing

Elen Orsini has left the Brazilian Federal Revenue Service and joined Machado Associados.
June 14 2010
This content is from: India

Indian firm grows practice

As part of a firm-wide restructuring, Vaish Associates has promoted two transfer pricing associates to salaried partner level.
June 10 2010
This content is from: Switzerland

Akin Gump opens Geneva office

Akin Gump Strauss Hauer & Feld is opening a new office in Geneva, Switzerland. New partner Jonathan Ivinson has significant transfer pricing experience.
June 10 2010
This content is from: Transfer Pricing

Mexican authorities extend filing deadline

The Mexican tax authorities have extended the deadline for companies to submit their 2009 statutory tax reports (dictamen fiscal), though advisers say that transfer pricing documentation still needs to be ready well i...
June 10 2010
This content is from: Transfer Pricing

OECD review of guidelines renews debate over arm’s length standard

The OECD will review and revise its transfer pricing guidance on intangibles later this year in an effort to clarify one of the most frustrating and notoriously inconsistent areas of international tax.
June 09 2010
This content is from: Canada

Attrition and new initiatives cause delays at Canada Revenue Agency

Advisers report consistent attrition at Canada Revenue Agency (CRA) and this along with new initiatives and internal protocols is causing a severe backlog in audits and advance pricing agreement (APA) applications.
June 08 2010
This content is from: India

Court clarifies criteria for fixed place PE

An Indian court has outlined the three criteria that taxpayers must satisfy to constitute a fixed place permanent establishment.
June 08 2010
This content is from: United States

Updated: MAP agreement is logical say advisers

A mutual agreement between the Netherlands and the US which amends the procedure of obtaining an exemption from dividend withholding tax under the Netherlands-US tax treaty makes sense as it affords the US government ...
June 08 2010
This content is from: United States

Businesses concerned about new transfer pricing challenges

Tax directors from multinational companies expressed alarm over shifts in transfer pricing trends during a panel at the joint American Bar Association and International Fiscal Association event in Copenhagen.
June 08 2010
This content is from: India

Delhi tribunal rules on non-operating income

The Delhi bench of the Income-tax Appellate Tribunal has upheld the exclusion of non-operating incomes like interest, dividends and income from share trading while determining profit margin under the transactional net...
June 07 2010
This content is from: Brazil

Brazilian taxpayers left unsure as to which rules to follow

New transfer pricing rules failed to be passed into law within the Constitutional deadline, creating controversy as to which rule applies to transactions carried out since the beginning of the year.
June 06 2010
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OECD promotes Brazil & Indonesia to white list

Brazil and Indonesia have substantially implemented the internationally agreed tax standard for transparency and exchange of information, according to an updated OECD progress report.
June 03 2010
This content is from: United States

The Netherlands and US settle mutual agreement

A mutual agreement has been settled between the competent authorities of the Netherlands and the US which amends the procedure by which US pension funds obtain an exemption from dividend withholding tax under the Neth...
June 01 2010
This content is from: Transfer Pricing

Study recommends stricter transfer pricing rules for Africa

An annual study has called for African countries to deal with transfer pricing abuse to help move towards more effective, efficient and fair taxation across the continent. While in South Africa, new transfer pricing p...
June 01 2010
This content is from: Australia

Australia releases ruling on business restructuring

The Australian Tax Office (ATO) has today released a draft taxation ruling on the application of transfer pricing provisions in business restructurings.
June 01 2010
This content is from: Italy

Italy releases new transfer pricing documentation rules

On May 31 the Italian government issued law decree number 78 (to be converted into law within a 60 day maximum term) that introduces transfer pricing documentation requirements in the Italian statutes.
June 01 2010

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