Transfer Pricing

Archive: Transfer Pricing

This content is from: Belgium

Belgium clarifies requirements for tax haven payment reporting

The Belgian tax authorities have finally published a circular clarifying the scope of a year-old law, requiring companies to report all payments made to tax havens that are more than a total of €100,000 ($131,000) in ...
December 22 2010
This content is from: United States

Transfer pricing rules can decelerate movement of undeclared funds

As emerging economies struggle with the prospect of inflation and depreciation, which some tax markets fear could repeat the 1997 Asian Financial Crisis, transfer pricing rules could become increasingly important.
December 22 2010
This content is from: France

France’s amendment to thin cap rules will affect bank loans

The French Parliament, on December 15, adopted an amendment to the thin capitalisation rules, bringing all financing between related parties, within the scope of the limitations of the rules.
December 22 2010
This content is from: India

India thinks again about safe harbour rules

India’s Finance Ministry is reconsidering the introduction of safe harbour rules because of the difficulties in implementing them.
December 22 2010
This content is from: Italy

Italian circular says taxpayers must provide transfer pricing documentation

Multinational companies in Italy run the risk of being audited if they do not comply with new guidance on transfer pricing documentation.
December 20 2010
This content is from: Switzerland

How debt-financing cut Boots tax bill by £80 million

A chain of pharmacies has cut its UK tax bill by £80 million ($125 million) since it left the London Stock Exchange and moved its tax residency to Switzerland, despite a rise in sales and trading profits.
December 20 2010
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Hot money getting colder for US investors

Tax practitioners believe another programme of quantitative easing (QE) for the US banking system will see more barriers such as Brazil’s IOF (Financial Operations Tax), being put up to prevent inflation, shutting out...
December 16 2010
This content is from: Transfer Pricing

Reuters improves transfer pricing software

Thomson Reuters has added new tools to its Documenter software, a key component to its comprehensive ONESOURCE Transfer Pricing offering.
December 15 2010
This content is from: India

Cheil Communications case sets precedent in India

Cheil Communications India, a subsidiary of South Korea’s largest advertising agency, has won its appeal at the Indian Income Tax Appellate Tribunal (ITAT) over pass-through costs in a case that sets a precedent for f...
By Salman Shaheen
December 15 2010
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Magnifying the fine print in Toepfer

Guillermo Teijeiro and Ana Lucía Ferreyra, tax partners at Negri & Teijeiro Abogados in Argentina, delve into the specifics behind the case of Administración Federal de Ingresos Públicos v Alfred C Toepfer Internacion...
December 14 2010
This content is from: Egypt

Egypt releases transfer pricing guidelines

The Egyptian Tax Authority (ETA) has launched transfer pricing guidelines, after the introduction of legislation in 2005.
December 13 2010
This content is from: Brazil

New decision on transfer pricing “may become important precedent” in Brazil

Cristiane M. S. Magalhães and Iara M. S. Sousa do Amaral of Machado Associados explains why a decision of the Federal Regional Court of Appeals of the 3rd region (TRF) may become an important precedent for transfer pr...
December 13 2010
This content is from: United Kingdom

UK’s Finance Bill 2011 clarifies use of new OECD guidelines

Draft clauses for Finance Bill 2011 in the UK refer to the updated OECD guidelines of July 2010 and make clear that, for accounting periods beginning on or after April 1 2011, this version is the one for business to ...
December 10 2010
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Commodities exporter comes away with win against Argentine Revenue Service

Four months after the Tribunal Fiscal de la Nación, or Argentine Tax Court, determined the case of Administración Federal de Ingresos Públicos v Alfred C Toepfer Internacional, the decision has finally been made publi...
December 09 2010
This content is from: Netherlands

SABMiller accused of using transfer pricing abuses in developing countries

ActionAid, the UK-based development agency, has accused SABMiller, a multinational brewing and bottling company, of using transfer pricing to lower its tax bills in developing countries.
December 08 2010
This content is from: India

Indian tribunal favours taxpayer over arm’s length payment of royalty for technical ser...

The Delhi Income Tax Appellate Tribunal upheld, in the case of Abhishek Auto Industries, the company’s arm’s-length justification of the payment of a royalty fee for technical know-how and assistance to a manufacturin...
December 08 2010
This content is from: United States

Canada prepares to implement arbitration

The US-Canada arbitration provisions represent a turning point in cross-border transfer pricing negotiations between the two trading partners.
December 08 2010
This content is from: Vietnam

Vietnamese tax haven list means anti-abuse rules are “not far off”

The Vietnamese government has released a list of jurisdictions that it considers to be tax havens. The list includes the British Virgin Islands (BVI), as well as Bosnia-Herzegovina, UAE, Lithuania, Albania and a numbe...
December 08 2010
This content is from: Transfer Pricing

Tax hike stops Fiji water flow

A two-year transfer pricing dispute between the Fijian tax authority and the US subsidiary of Fiji Water has escalated in recent weeks with the company cancelling operations after the government raised tax dramatically.
December 07 2010
This content is from: United States

Arbitration memorandum finds common ground between US and Canada

Canadian and US tax authorities released a memorandum of understanding (MOU) on November 26 about the mandatory binding arbitration proceedings under the mutual agreement procedure (MAP) of the US-Canada tax treaty.
December 07 2010
This content is from: European Union

EU transfer pricing adviser seeks more clarity from OECD

A member of the EU Joint Transfer Pricing Forum has said the latest changes to the OECD transfer pricing guidelines fall into three categories.
December 01 2010
This content is from: Canada

Advisers predict CRA will increase transfer pricing audits

Diminishing revenues because of economic turmoil across the globe is leading tax authorities to increase their enforcement activity, especially in transfer pricing.
By Erin Kelechava
December 01 2010
This content is from:

Indian tribunal finds taxpayer did not meet burden in management fees case

An Indian Income Tax Appellate Tribunal (ITAT) has ruled that a charge for services or intangibles must meet certain requirements to satisfy the arm’s length standard.
December 01 2010
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Canadian companies should brace for increased audits

Canadian multinationals can expect to face more audits in the coming years as the Canada Revenue Agency (CRA) focuses on enforcement activity.
December 01 2010
This content is from: Japan

Japan records fewer transfer pricing cases and more revenue

The National Tax Agency (NTA) of Japan has released statistics for tax audits, year ending June 30 2010 (FY 2009).
December 01 2010
This content is from: India

Indian Supreme Court directs officer to continue reassessment

In the Coca Cola India case the Supreme Court said that, because the writ position could not establish the facts of the case, the taxpayer must adopt proceedings before the assessing officer or transfer pricing office...
December 01 2010
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Russia moves towards transfer pricing norms

Russia's new draft law has many of the features of international systems, such as contemporaneous documentation, guidance on the use of new methods and advance pricing agreements, explain Svetlana Stroykova and Evgeni...
December 01 2010

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