Transfer Pricing

Archive: Transfer Pricing

This content is from: China

China settles as many TP investigations as it initiates

China’s State Administration of Taxation (SAT) has confirmed it initiated 178 transfer pricing investigations in 2010 and concluded the same amount.
April 27 2011
This content is from: Thailand

Thai TP questionnaire is more trouble than financial statement

The Thai Revenue Department (TRD) has issued a questionnaire for taxpayers to provide details of their related-party transactions, increasing the scrutiny they apply to transfer pricing arrangements.
April 26 2011
This content is from: Transfer Pricing

Mexico intangibles guide

By Daniela Camargo, Marta Milewska and Fred Barrett of PwC
April 25 2011
This content is from: Transfer Pricing

TP panel at Asia forum will live up to reputation

The transfer pricing panel at International Tax Review’s annual Asia Forum in Singapore next month promises to live up to its reputation as one of the most popular panels at the event.
April 25 2011
This content is from: Australia

Australia intangibles guide

By Paul Balkus and Melissa Heath of Ernst & Young
April 25 2011
This content is from: India

SPECIAL FEATURE: Crying out for the inter-quartile range

A campaign is building for the introduction of the inter-quartile range and the acceptance of multiple-year data for transfer pricing documentation in India – a country that goes against the global best practice.
April 25 2011
This content is from: European Union

Updated EU Joint TP Forum members

The updated members list for the EU Joint Transfer Pricing Forum (JTPF) has been announced. Their mandate is effective from April 1 2011.
April 25 2011
This content is from: European Union

Luxembourg further clarifies transfer pricing rules

The tax authorities in Luxembourg issued Circular LIR 164/2 bis, on April 8, which serves to clarify transfer pricing rules for resident taxpayers.
April 19 2011
This content is from: United Kingdom

Global TP survey gets a mixed reaction

When Dave Hartnett, HMRC's permanent secretary for tax, told the Tax Planning Strategies meeting in Paris, organised by the IBA, the ABA, IFA and the OECD, that the UK is to lead a survey into the practicality of glob...
April 19 2011
This content is from: Australia

IBM loses out to ATO on royalties

Computer company IBM has lost a two-year dispute with the Australian Tax Office (ATO) over royalties paid to its American parent.
By Salman Shaheen
April 19 2011
This content is from: United States

US APAs more popular than ever

Advance pricing agreements (APAs) in the US continue to grow in popularity, statistics indicate.
April 18 2011
This content is from: Transfer Pricing

Silberztein lists possible future work for OECD intangibles project

Caroline Silberztein, head of the OECD’s transfer pricing unit, has said the organisation's guidance on intangibles is insufficient, as it stands, and considered old and out-of-date.
By Sophie Ashley
April 13 2011
This content is from: United Kingdom

UK to lead global transfer pricing survey

The top official at HM Revenue & Customs confirmed that the UK is to lead a survey into the practicality of global transfer pricing guidelines.
April 13 2011
This content is from: Transfer Pricing

Intangibles’ 2013 discussion draft is “ambitious”

The deadline for the OECD's project on the transfer pricing aspects of intangibles has been described as ambitious by some and unrealistic by others.
By Sophie Ashley
April 13 2011
This content is from: United States

Bloomberg declines to appeal Russian PE precedent

Media company, Bloomberg, will not appeal a Russian court decision that said its Russian operations constituted a permanent establishment (PE).
April 12 2011
This content is from: Ireland

Ireland reluctant to act on charities’ transfer pricing adjustment demands

The Department of Finance in Dublin said it is unlikely to adopt the recommendations of a group of six Irish charities to adapt the transfer pricing regime.
April 12 2011
This content is from: Qatar

New Qatar law impacts TP

A new tax law is effective in Qatar with specific transfer pricing implications, including advance rulings.
April 12 2011
This content is from: India

New TP India services initiative
April 12 2011
This content is from: Germany

German auditor numbers increasing

The number of field audits may be increasing globally, but the auditors’ approach in each jurisdiction is not the same.
April 12 2011
This content is from: Norway

Court rules commissionaire constitutes PE

A Norwegian Court of Appeal ruled on March 2 that Dell AS, a Norwegian commissionaire company, constituted a sales agency permanent establishment (PE) in Norway because of its undisclosed Irish principal.
April 10 2011
This content is from: India

New TP practice
April 06 2011
This content is from:

European Awards nominees published

The shortlists for International Tax Review's European Tax Awards have been announced.
April 06 2011
This content is from: India

Experts’ opinion to be used in complex or costly TP cases

A decision of the Supreme Court will give taxpayers involved in contentious matters in India the chance to deal with specialists in the future.
April 05 2011
This content is from: United States

AstraZeneca discusses APA settlement

Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC).
April 05 2011
This content is from: Ireland

Charities ask Ireland to lead way on TP reform

Six Irish charity organisations, collectively called the Debt and Development Coalition Ireland (DDCI), have called on their government to reform the transfer pricing regime.
April 05 2011
This content is from: United States

IRS expands scope of cost sharing regulations

The IRS has issued a Chief Counsel Advisory (CCA) discussing the application of the valuation methods described in the temporary cost sharing regulations.
April 05 2011
This content is from: France

France intangibles guide

By Sylvain Chevrier of Taj, Société d’Avocats, member of Deloitte
April 04 2011
This content is from: Finland

Finland intangibles guide

By Hannu-Tapani Leppänen and Reima Linnanvirta of Alder & Sound
April 04 2011

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