This content is from: China APA process in China fails to meet taxpayers’ needs despite breakthroughs China completed its second bilateral advance pricing agreement (BAPA) in October. However, some transfer pricing professionals believe the process is not working properly. November 30 2010
This content is from: Ireland Transfer pricing is biggest economic barrier to decreasing Northern Ireland’s corporate... Transfer pricing could be the biggest obstacle to equalising the corporate tax rate in the north and south of Ireland, a UK parliamentary committee has been told. November 29 2010
This content is from: Transfer Pricing Honduras to introduce transfer pricing rules Honduras is preparing new legislation to combat tax evasion, including a chapter on transfer pricing, as part of its fiscal reform. November 24 2010
This content is from: Belgium Lack of thin capitalisation rule gives taxpayer victory in India The Income Tax Appellate Tribunal (ITAT) has held that tax planning carried out within the provisions of the law cannot be classed as a structured transaction for tax evasion purposes, even if the structure saves the ... November 24 2010
This content is from: Brazil Transfer pricing inspections do not focus on services Cristiane Magalhães and Angélica Santos Torres of Machado Associados examine the changing situation in Brazilian transfer pricing November 24 2010
This content is from: Venezuela Venezuela transfer pricing authorities flex their muscles Venezuelan tax authorities have penalised 68 taxpayers that failed to comply with the country’s transfer pricing rules. By Erin Kelechava November 24 2010
This content is from: India ITAT ruling on the transfer pricing aspects of management services fees The Bangalore Income Tax Appellate Tribunal (ITAT) has ruled in favour of the Commissioner of Income Tax in the case of Gemplus India Pvt. November 24 2010
This content is from: United States US Tax Court and IRS at odds over transfer pricing in Veritas The IRS’ Action on Decision (AOD), on November 10 2010, stating it does not agree with the result or reasoning of the US Tax Court’s decision in Veritas Software Corp. v. Commissioner, brought a spectrum of transfer p... November 24 2010
This content is from: Indonesia Indonesia amends double taxation regulation The Tax Directorate General in Indonesia has issued a new regulation on the Joint Agreement Procedure Implementation System to avoid double taxation. November 17 2010
This content is from: Colombia Colombia changes disclosure requirements Fabian Alfonso and Diana Mogollón of BaseFirma believe the tax authorities will only continue to increase the compliance burden for taxpayers November 17 2010
This content is from: Transfer Pricing OECD to issue review of hindsight The OECD has sent a questionnaire to all member countries asking them how they deal with the issue of hindsight when forecasting the profits arising from intangibles. November 17 2010
This content is from: United Kingdom Developing countries left behind despite international focus on transfer pricing Developing countries may not be getting the full benefit of an increased international focus on transfer pricing, says Christian Aid’s senior economic justice adviser. November 17 2010
This content is from: Transfer Pricing CIOT launches transfer pricing examination The Chartered Institute of Taxation (CIOT) is launching a transfer pricing option examination paper as a global benchmark of quality and achievement and an independent means of demonstrating transfer pricing expertise. November 17 2010
This content is from: India APAs are India’s “biggest hope”, says panel The introduction of advance pricing agreements in India has been heralded as the “biggest hope” for transfer pricing in the country, said a panel of top Indian tax professionals. By Jack Grocott November 12 2010
This content is from: The effect of the Veritas Software case in resolving similar disputes pending before th... On November 10 2010 the IRS issued an Action on Decision (AOD) stating its position on the Veritas case. November 12 2010
This content is from: IRS will not appeal Veritas case The Internal Revenue Service (IRS) has chosen not to continue its fight against the Tax Court’s ruling in the Veritas transfer pricing case, but that does not mean that the agency agrees with the decision. November 11 2010
This content is from: United States Resolution of FMC row is “tip of the iceberg” for disputes On November 3, FMC Technologies (FMC), an oil and gas equipment services company, announced that it reached a resolution with the IRS about a proposed adjustment to the company’s federal income tax returns for the 200... November 10 2010
This content is from: United Kingdom Advance pricing agreements offer audit assurance Shiv Mahalingham of Alvarez & Marsal (Taxand UK) deconstructs international approaches to APAs and explains how the agreements can help prevent unexpected adjustments, interest or penalties in transfer pricing audits. November 10 2010
This content is from: The new International Tax Review website is now live The new www.internationaltaxreview.com includes a new publication and organises information in a clearer, logical way. By Ralph Cunningham November 10 2010
This content is from: Transfer Pricing OECD wants to better define the transfer pricing aspects of intangibles The OECD’s Working Party 6, of the Committee on Fiscal Affairs, met yesterday in Paris to discuss a new project on the transfer pricing aspects of intangibles, which may lead to a revision of chapters six and eight of... November 10 2010
This content is from: Indonesia A new era of transfer pricing in Indonesia Douglas Fone, Global Partner of Transfer Pricing Associates, explores the implications of new transfer pricing guidelines in Indonesia November 10 2010
This content is from: Transfer Pricing Kazakhstan chases one of its biggest taxpayers The Kazakhstan tax authorities have made a $1.2 billion claim, including transfer pricing charges against the Karachaganak Petroleum Operating Group (KPO) for unpaid taxes between 2005 and 2008, a Reuters report revea... November 10 2010
This content is from: Take part in the Latin America Client Services Poll Executives responsible for the Latin America region often claim they have the most difficult job in the tax department. And this claim seems justified. November 09 2010
This content is from: Australia ATO ruling causes controversy over arm’s-length interest The Australian Tax Office (ATO) has published the final version of a controversial Taxation Ruling (TR 2010/7) about the interaction between the country’s transfer pricing and thin capitalisation rules. November 03 2010
This content is from: Norway Norwegian tax authorities intensify transfer pricing efforts Norway has stepped up its scrutiny of related-party transactions, explain Merethe Bryn and Amrit Paul Singh of Deloitte November 03 2010
This content is from: Philippines Philippines steps up audit pressure Philippine government sources indicated this week that the Bureau of Customs (BOC) is profiling vehicle imports from a number of other companies which have been allegedly undervalued. November 03 2010
This content is from: India Supreme Court proposes domestic transactions should come within Indian transfer pricing... Rohan Phatarphekar and Vinita Chakrabarti of KPMG discuss the case which led the Supreme Court to suggest that the transfer pricing rules should also apply to domestic transactions November 03 2010
This content is from: Transfer Pricing OECD moves ahead with intangibles project An OECD consultation may lead to an update to its transfer guidelines on transfer pricing on the issue of intangibles and cost-sharing arrangements said David Ernick, associate international tax counsel at the US Depa... By Erin Kelechava November 02 2010
This content is from: The DTC through a magnifying glass Ashesh Safi and Geeta Ramrakhiani of Deloitte analyse the implications of the new direct tax code and discover that there is a lot more to the new code than meets the eye and that achieving a simple and efficient tax ... November 01 2010
This content is from: Indian advisers anxious about transfer pricing under the DTC By Jack Grocott November 01 2010
This content is from: Deloitte strengthens UK practice Deloitte in the UK has appointed Heather Devine as a director within its business model optimisation team, part of the transfer pricing group. November 01 2010
This content is from: Transforming India's transfer pricing landscape With 2011 heralding a decade since transfer pricing provisions were introduced in India, Srinivasa Rao and Rajendra Nayak of Ernst & Young explain how recent landmark decisions are likely to have a significant impact ... November 01 2010
This content is from: Predicting India's future For a long time the Indian tax community has bemoaned the unpredictability of the tax system. While the Direct Tax Code and a national goods and services tax, for example, promise to make things more stable, no one ca... November 01 2010
This content is from: Twenty-one years in tax As International Tax Review celebrates its 21st birthday in November 2010, Erin Kelechava takes the opportunity to look back at a selection of the notable events in tax since 1989. November 01 2010
This content is from: Sponsored Changes to transfer pricing and thin capitalisation South Africa's Taxation Laws Amendment Bill has radically altered the country's transfer pricing and thin capitalisation rules. By ITR Correspondent November 01 2010
This content is from: The 21 biggest influences in tax today To mark the 21st birthday of International Tax Review in November 2010, the editorial staff of the magazine decided to choose the 21 most influential people or organisations in tax today. November 01 2010
This content is from: New firms take home awards Taxpayers and advisers came out on the night of September 29 for International Tax Review's fifth annual Americas Awards at the Waldorf-Astoria hotel in New York. November 01 2010
