This content is from: OECD has work to do on APA guidelines Caroline Silberztein, head of the transfer pricing unit in the OECD centre for tax policy and administration answers Catherine Snowdon's questions about the problems that face APA programmes today and how the OECD wil... August 31 2010
This content is from: Denmark Danish tax authorities release tax action plan The Danish tax authorities have caused a stir among corporate taxpayers by releasing an action plan which will probably lead to a crack down on transfer pricing. August 31 2010
This content is from: Chile: Unclear if OECD principles apply to local rules In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed. August 31 2010
This content is from: Brazil: Caution advised to avoid disaster Simone Dias Musa, Clarissa Machado and Camilla Lagrasta explain how not following the OECD guidelines makes the Brazilian rules difficult to follow. With fixed margins regardless of industry and new thin capitalizatio... August 31 2010
This content is from: Venezuela: Taxpayers are at risk of severe penalties Ronald Evans and Gustavo Sánchez discuss Venezuela's complex rules and explain that taxpayers must strive to comply with the legislation or face heavy penalties. August 31 2010
This content is from: Brazil publishes its black and greylists Andrea Bazzo Lauletta and Luiz Felipe Centeno Ferraz of Mattos Filho, of Veiga Filho, Marrey Jr e Quiroga Advogados in Brazil explain how the country is modernising its categorisation of tax havens and privileged tax ... August 31 2010
This content is from: Canada Taxpayers to seek advice on marketing intangibles Marketing intangibles is something that taxpayers should not take lightly as no single approach applies to all business, says one leading transfer pricing adviser. August 31 2010
This content is from: Colombia: Getting documentation right is crucial for taxpayers Transfer pricing legislation is relatively new in Colombia and with taxpayers, advisers and officials still finding their way, questions are still being asked. Diego González-Béndiksen and Rhina Toro Infante warn seve... August 31 2010
This content is from: Sponsored Brazilian authorities update their black list of tax haven jurisdictions Since June 2008, when a broadened definition of low-tax jurisdictions (tax havens) was introduced by the authorities, taxpayers have been eagerly awaiting the enactment of an updated black list of tax haven jurisdicti... By PwC Brazil August 31 2010
This content is from: India New Indian Direct Tax Code spells change On August 30 2010, the Indian government tabled a Direct Tax Code Bill 2010 in the parliament. The new code aims to replace the Income Tax Act 1961 and the Wealth Tax Act 1957. If enacted, it will be effective from Ap... August 31 2010
This content is from: Mexico: Moving forward along a different path In Mexico, the transfer pricing rules have been in force since 1997, a relatively long time in Latin America. Moisés Curiel, Carlos Linares and Emilio Angeles talk taxpayers through staying on the right side of the no... August 31 2010
This content is from: Peru: Transfer pricing rules are developing rapidly Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important poin... August 31 2010
This content is from: Argentina: Transfer pricing rules in need of change Augusto Martín Camarero and Armando Cabrera describe the way Argentine transfer pricing rules still fall behind more developed tax codes. The lack of advance pricing agreements and quasi acceptance of secret comparabl... August 31 2010
This content is from: Australia Australian Tax Office appeals SNF decision The Australian Taxation Office (ATO) has lodged an appeal to the Full Federal Court of Australia against the recent transfer pricing decision in the SNF case. August 31 2010
This content is from: United States Future of the arm’s-length standard up for discussion The first topic up for discussion at International Tax Review's Global Transfer Pricing Forum in Amsterdam next month is the future of the arm’s-length standard. August 31 2010
This content is from: United States Sourcing operations to spark debate Taxpayers need to pay special attention to the structures and value-added approaches to their sourcing operations, a group of leading tax professionals has said. August 31 2010
This content is from: Ecuador: Taxpayers racing to catch up as new rules settle in With transfer pricing rules only introduced in 2005, Ecuador is still feeling its way through the implications. Diego González-Béndiksen and Diego Almeida talk through what taxpayers can and cannot do under the fledgl... August 31 2010
This content is from: Uruguay: Newcomers to transfer pricing are still learning With enactments of important rules only taking place in 2009, transfer pricing regulations are still very new in Uruguay. Jonás Bergstein and Domingo Pereira explain how the new rules are changing business practices i... August 31 2010
This content is from: United States Panellists to share dispute resolution experiences The dispute resolution panel at International Tax Review's Global Transfer Pricing Forum will focus on planning transfer pricing policies to avoid disputes, achieving settlements and using advanced pricing agreements ... August 31 2010
This content is from: China Bilateral advance pricing arrangement signed in Shanghai After several years of competent authority discussion, a home appliances manufacturer has agreed terms on an advance pricing agreement (APA) with the Chinese tax authorities. August 30 2010
This content is from: United States Joint Committee‘s budget analysis shows more pro-corporate slant The report from the Joint Committee on Taxation (JCT) on President Obama's 2011 budget, provides revenue estimates for each of the tax provisions in the budget, including proposals about transfer pricing and treatment... August 30 2010
This content is from: Australia Baker & McKenzie hires new Australian partner The international firm has brought in a solicitor and chartered accountant. August 26 2010
This content is from: United Kingdom New keynote speaker announced for Global Transfer Pricing Forum A valuation specialist from the World Customs Organisation (WCO) will give a keynote address at International Tax Review’s Global Transfer Pricing Forum in Amsterdam on September 15 and 16. August 24 2010
This content is from: United States Nominees for Americas Tax Awards unveiled International Tax Review will present its fifth annual Americas Tax Awards at the Waldorf-Astoria Hotel in New York on September 29 2010. August 24 2010
This content is from: United States IRS reorganisation signals more intensive approach to transfer pricing The Large and Mid-Size Business division of the Internal Revenue Service (IRS) will become the Large Business and International (LB&I) division on October 1 in a move that signals a greater focus on transfer pricing. August 23 2010
This content is from: Canada CRA continues to grow mutual agreement procedure programme The Canadian mutual agreement procedure (MAP) programme saw an increase in the number of accepted and completed cases in the past year. August 18 2010
This content is from: Brazil Brazil’s transfer pricing rules v OECD’s guidelines Tatiana Villani and Anna Cecília Brasil of Machado Associados comment on the main differences between Brazil’s transfer pricing rules and the OECD’s guidelines, and the difficulties and opportunities that this may cre... August 16 2010
This content is from: United States Baker & McKenzie adds new partner Russell Young has joined Baker & McKenzie in Chicago as a partner. August 16 2010
This content is from: Japan Authorities make $270 million claim against HP The Japanese tax authorities have ordered Hewlett-Packard Japan to pay ¥23 billion ($270 million) in unpaid taxes. August 12 2010
This content is from: Canada Former national coordinator highlights Canadian APA approach Shiraj Keshvani served until March this year as the chief economist for Canada Revenue Agency’s (CRA’s) competent authority services division and was the national coordinator for the advance pricing arrangement (APA) ... August 12 2010
This content is from: United States KPMG adds two specialists in DC KPMG has hired two new practitioners with experience of working for the IRS. August 12 2010
This content is from: United States US makes changes to business compliance The US government has decided to reorganise its efforts in international tax administration in an effort to improve compliance. August 05 2010
This content is from: Australia Simpson leaves ATO A senior transfer pricing official from the Australian Taxation Office is leaving to rejoin Deloitte after 10 years with the tax authorities. August 03 2010
This content is from: United Kingdom UK Pensions Regulator investigates Nortel’s transfer pricing The UK Pensions Regulator’s decision to issue its second ever Financial Support Direction against 25 companies in the Nortel Group in Canada, the US, Europe and Africa is because, in part, of an investigation into th... August 03 2010
This content is from: Canada Active cases in Canada’s APA programme grow, but so do withdrawals The period of Canada’s Advance Pricing Arrangement (APA) programme that concluded on March 31 2010 saw an all-time high in active cases, but questions about staffing issues still linger. By Erin Kelechava August 03 2010
This content is from: Canada Glaxo prevails in the Canadian Federal Court of Appeal GlaxoSmithKline Canada has won its appeal against a 2008 judgment by the Tax Court of Canada that it paid a Swiss related party too much money for the active ingredient in Zantac. August 01 2010
