This content is from: Transfer Pricing OECD releases intangibles scoping document The OECD has released a scoping document on the transfer pricing aspects of intangibles in response to its consultation on the topic last year. By Salman Shaheen January 31 2011
This content is from: OECD elects new fiscal affairs chairman The OECD has revealed that Masatsugu Asakawa is to be appointed the new chairman of its Committee on Fiscal Affairs (CFA). By Matthew Gilleard January 31 2011
This content is from: Transfer Pricing OECD elects new fiscal affairs chairman The OECD has revealed that Masatsugu Asakawa is to be appointed the new chairman of its Committee on Fiscal Affairs (CFA). January 31 2011
This content is from: United States Ceteris hires two new US transfer pricing specialists The transfer pricing and valuation consultants have added advisers to its practices on the east and west coasts. January 31 2011
This content is from: Transfer Pricing Uphill struggle convincing firms to back country-by-country reporting Five asset management and research firms have signed up to a Global Financial Integrity (GFI) initiative on financial transparency. January 26 2011
This content is from: India Transfer pricing alone “is not enough” to repatriate Indian black money India’s Finance Minister said yesterday that an upgrade was needed to bring the country’s transfer pricing norms into line with global standards. January 26 2011
This content is from: Venezuela Venezuelan procedure for calculation of arm’s length range The Venezuelan Tax Administration has introduced the procedure for the calculation of the arm’s length range for compliance with the country’s transfer pricing rules. January 26 2011
This content is from: European Union Commission to extend mandate of EU Joint Transfer Pricing Forum The European Commission announced yesterday it will extend the mandate of the EU Joint Transfer Pricing Forum (JTPF) until March 2015. January 26 2011
This content is from: China Case sheds light on future for Chinese transfer pricing A recent transfer pricing dispute in China has reiterated the country’s shift from enforcement and administration towards complex transfer pricing issues and alignment with internationally recognised practices. By Jack Grocott January 26 2011
This content is from: Case sheds light on future for Chinese transfer pricing A recent transfer pricing dispute in China has reiterated the country’s shift from enforcement and administration towards complex transfer pricing issues and alignment with internationally recognised practices. By Jack Grocott January 26 2011
This content is from: Transfer Pricing Transfer pricing attitudes are a “vicious circle” As audit activity increases, on a global scale, transfer pricing documentation is becoming critical to multinational companies. January 26 2011
This content is from: France French use dawn raids to crack down on PEs The French tax authorities (FTA) have been conducting raids on the offices of French companies in an attempt to prove the existence of permanent establishments (PE). January 24 2011
This content is from: China NERA adds transfer pricing staff to Beijing Sébastien Gonnet recently transferred to NERA’s Beijing office. January 20 2011
This content is from: Italy TPA Associates strengthens its Italian practice Enrico De Angelis and Caterina Colling have both joined joined the TPA team in Italy. January 20 2011
This content is from: India ITAT rules on pricing method of generic active pharmaceutical ingredients (API) Rohan Phatarphekar and Manish Bafna, of KPMG, dissect the Mumbai ITAT ruling in the case of Serdia Pharmaceuticals and explain why APIs can constitute a comparable uncontrolled price (CUP) for the import of drugs when... January 19 2011
This content is from: Finland Finnish court sets precedent on arm’s length interest in intra-group financing In a decision that represents binding case law, the Supreme Administrative Court in Finland has delivered a ruling on the determination of arm’s-length rate of interest in intra-group financing structures. January 19 2011
This content is from: Germany Former German thin capitalisation rules fail non-discrimination test The Supreme Tax Court in Germany has clarified that not only did the country’s old thin capitalisation rules not comply with the freedom of establishment provision of the European Community (EC) treaty, but they also ... January 19 2011
This content is from: Serbia Serbia to enforce transfer pricing rules more strictly Serbia plans to crack down on tax evasion by enforcing transfer pricing regulations more strictly as it tries to revive the economy after the international downturn. January 19 2011
This content is from: Transfer Pricing Mexico gives taxpayers leeway with MAP Taxpayers and revenue authorities in Mexico will have more time in a mutual agreement procedure because of a new rule introduced last month. January 19 2011
This content is from: South Korea Korea increases maximum penalty for non-compliance in a transfer pricing audit by more ... The maximum fine for a Korean taxpayer’s non-compliance in a transfer pricing audit has been increased from W30 million ($27,000) to W100 million. January 19 2011
This content is from: Indonesia Indonesia issues procedural requirements for APA programme Indonesia’s director general of taxation (DGT) has released Regulation No.69/2010, which outlines the procedural requirements taxpayers should follow if they want to obtain an advanced pricing agreement (APA). January 19 2011
This content is from: United States KPMG adds to transfer pricing team Kristin Yoshida has joined the Houston office of KPMG as a managing director of the transfer pricing services team. January 12 2011
This content is from: India India sets out five year plan to tackle tax leakage The Indian tax department has released a five-year vision statement, which mentions forming a group of experts, by March this year, to tackle tax leakage and transfer pricing. January 12 2011
This content is from: Argentina Agribusinesses face transfer pricing accusations in Argentina Nidera, an Argentine grain producer and distributor, is being investigated by the Argentine revenue authority (AFIP), after being accused of transfer pricing manipulation. January 12 2011
This content is from: Thailand Thai revenue authority needs to look at thin capitalisation says top official The Thai revenue department intends to look at how it could reform its transfer pricing regulations, in particular, by introducing thin capitalisation rules, to increase revenue collection and close loopholes. January 12 2011
This content is from: Japan Japan’s tax reform includes most appropriate method in transfer pricing proposals The proposed 2011 Japan tax reform includes transfer pricing recommendations designed to mirror the changes made to the OECD guidelines, which were updated last year. January 12 2011
This content is from: United States US Competent Authority is resolving more cases but taking more time The most recent set of US competent authority statistics, for fiscal year ending September 30 2010, show the authority completed more cases than in any of the previous five years but the overall processing time has in... By Sophie Ashley January 12 2011
This content is from: Netherlands Lawyers launch new practice A new transfer pricing consultancy opened its doors in Amsterdam on November 1. January 12 2011
This content is from: India authorities target avoidance by opening eight more offices abroad The Indian government has announced that it is to open eight overseas tax offices in an effort to improve tax information exchange and reduce tax evasion. January 12 2011
This content is from: China New regulatory and tax environment for Chinese representative offices Representative offices (RO) and other foreign employees, who split their salary payments between China and their home country, may need to comply with China’s transfer pricing regulations for the 2010 audit period. January 12 2011
This content is from: Netherlands Lawyers launch new practice A new transfer pricing consultancy opened its doors in Amsterdam on November 1. January 10 2011
This content is from: United States KPMG adds to transfer pricing team Kristin Yoshida has joined the Houston office of KPMG as a managing director of the transfer pricing services team. January 10 2011
This content is from: Turkey TPA picks up Turkish partner Transfer Pricing Associates, the independent provider of transfer pricing and valuation services around the world, has added to its list of strategic allies. January 10 2011
This content is from: India Key Indian transfer pricing cases and legislation In light of several recent developments in Indian transfer pricing, Rohan Phatarphekar and Vinita Chakrabarti, of KPMG, provide an overview of key cases and legislation. January 05 2011
This content is from: China China issues its first-ever APA report China has joined Korea, Japan, the US, Canada, Australia and Italy as one of the first countries to issue a comprehensive report about its Advance Pricing Arrangement (APA) programme. Spencer Chong, Qisheng Yu, and St... January 05 2011
This content is from: United States IRS lands Boston Scientific with $525 million bill in transfer pricing dispute Boston Scientific, an international producer of medical devices, announced on Tuesday that the Internal Revenue Service (IRS) in the US has issued the corporation with a notice of deficiency, outlining unpaid taxes an... January 05 2011
This content is from: Transfer Pricing Read International Tax Review’s February issue for an insight into transfer pricing in ... Another year provides further scope for transfer pricing development. Tax directors, transfer pricing advisers and government officials are invited to share their views on what to expect from transfer pricing in 2011. January 05 2011
This content is from: New Zealand New bill changes thin capitalisation in New Zealand Changes to New Zealand’s thin capitalisation rules will come into effect on April 1 2011 as part of the Taxation (GST and Remedial Matters) Act. The act will limit foreign multinationals’ scope to reduce their New Zea... January 05 2011
This content is from: Canada Tax authorities lose appeal in GE Capital Canada case Canada’s Federal Court of Appeal (FCA) has dismissed the Crown’s appeal in the GE Capital Canada (GECC) transfer pricing dispute over the payment of a guarantee fee by a subsidiary to its parent. January 05 2011
This content is from: Russia Russian Parliament keeps taxpayers waiting for new transfer pricing rules Taxpayers in Russia will have to wait much longer than they thought for new transfer pricing rules after the State Duma failed to adopt the law in time for their enactment, as expected, on January 1. By Salman Shaheen January 05 2011
This content is from: Brazil Brazil removes Spanish international holding companies from the grey list of privileged... On December 2 2010 the Brazilian government granted the exclusion of Spanish holding companies (ETVEs) from its grey list of privileged tax regimes. Isabel Bertoletti, Fabíola Costa Girão and Henrique de Freitas Munia... January 05 2011
