Transfer Pricing

Archive: Transfer Pricing

This content is from: Brazil

Adjustments to business conditions

Cristiane Magalhaes and Victoria Rozsavolgyi of Machado Associados, Brazil, comment on the main aspects and difficulties of the adjustments to business conditions allowed by the Brazilian transfer pricing legislation ...
May 31 2011
This content is from: Austria

Austria intangibles guide

By Marianna Dozsa and Bettina Dorfer PwC, Austria
May 31 2011
This content is from: Transfer Pricing

Delays ahead for intangibles project

The resignations of Mary Bennett and Caroline Silberztein from the OECD last week provoked wide-spread speculation, above all because their jobs were advertised simultaneously, suggesting all is not well in the OECD’s...
May 31 2011
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Tips to survive your Vietnamese transfer pricing audit
May 31 2011
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Court of Appeal rules that a commissionaire company constitutes an agency PE of its pri...
May 31 2011
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Pakistan mulls documentation requirements
May 31 2011
This content is from: Transfer Pricing

Obama administration questions TP law

Two recent cases in the US, Medtronic and Guidant, highlight the Obama administration’s budget proposals to clarify the law regarding foreign intangible assets.
May 31 2011
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Asia directors unveil long list of concerns

After last month’s Asia Tax Executives’ Forum in Singapore, International Tax Review investigates the real issues Asian tax directors face on a daily basis as they experience greater scrutiny from authorities while at...
May 31 2011
This content is from: Transfer Pricing

OECD to shape ALP for developing countries

The OECD ministerial meeting in Paris had a strong focus on both tax and the developing world and, as such, transfer pricing issues were also raised.
May 31 2011
This content is from: China

China broadens audit focus

The Chinese State Administration of Taxation (SAT) has broadened its audit focus and will pay more attention to intangibles, controlled foreign companies (CFC) and thin capitalisation.
May 31 2011
This content is from: Belgium

Belgium intangibles guide

By Isabel Verlinden, Leticia Ortega and Jurgen Meersman of PwC, Belgium
May 26 2011
This content is from: Transfer Pricing

Nominees announced for Women in Business Law Awards

The leading female practitioners in Europe for tax, transfer pricing, tax dispute resolution and trusts and estates advice will be honoured at the first European Women in Business Law awards in London on June 29.
May 25 2011
This content is from: Australia

Australian reportable tax position may need APA support

The draft reportable tax position (RTP) schedule, effective July 1 2011, will require some corporate taxpayers to disclose information regarding reportable tax positions as a supplement to their annual income tax retu...
May 25 2011
This content is from: Transfer Pricing

DLA names new co-managing partner
May 25 2011
This content is from: Canada

Baker & McKenzie gain tax and TP partner
May 25 2011
This content is from: Canada

New Canadian ruling relied on expert evidence

In the Canadian Alberta Printed Circuits (APC) transfer pricing case, the decision relied extensively on the evidence given by expert witnesses on behalf of the taxpayer and the Canadian Revenue Agency (CRA).
May 24 2011
This content is from: France

Draft regulations on French thin cap rules disappoint professionals

Draft regulations on the French thin capitalisation rules have been released by the French tax authority (FTA).
May 24 2011
This content is from: Brazil

Brazil issues new thin capitalisation measures

Brazil has updated its guidelines for thin capitalisation, including new measures.
May 24 2011
This content is from: United States

American Apparel’s transfer pricing under scrutiny

Media reports suggest a US clothing manufacturer has been issued with a subpoena (government writ) over its transfer pricing, but the reasons remain unknown.
May 24 2011
This content is from: Canada

Canadian TP ruling favours taxpayer

In the latest transfer pricing case to emerge in Canada, the taxpayer has won a judgment from the Tax Court over reassessments made by the Canada Revenue Agency (CRA) worth about C$2.7 million ($2.7 million) even thou...
May 24 2011
This content is from: Spain

Spain intangibles guide

By Javier González Carcedo and Leticia Ortega of PwC, Spain
May 23 2011
This content is from: Transfer Pricing

IRS transfer pricing director named

The IRS has named Samuel Maruca, of Washington law firm, Covington & Burling, as its first transfer pricing director.
May 23 2011
This content is from: Transfer Pricing

Why Silberztein is quitting the OECD

The jobs of both Caroline Silberztein, the OECD's head of the transfer pricing unit in the tax treaty, transfer pricing and financial transactions division, and Mary Bennett, the head of the division itself, were adve...
May 23 2011
This content is from: Transfer Pricing

Comptroller and auditor general to review transfer pricing cases

While addressing a seminar organised by the Associated Chambers of Commerce and Industry of India, on May 12 2011, R N Dash, the director general of international tax, said transfer pricing cases shall now be subject ...
May 19 2011
This content is from: Russia

Permanent establishment: OECD vs UN treaty model

The permanent establishment (PE) panel at International Tax Review’s Asia Tax Executives’ Forum in Singapore last week discussed the movement of employees and to what extent this could constitute a PE.
May 17 2011
This content is from: Japan

Tohoku earthquake has transfer pricing aftershocks

On March 11, Japan was rocked by the most powerful earthquake it has ever recorded. But, following the devastation, wrought by the aftershocks and tsunami, the fallout was not just nuclear. The earthquake may have a n...
May 17 2011
This content is from: Russia

OECD welcomes Russian TP progress

The OECD has sent out a report that welcomes the Russian’s progress towards the revision of its transfer pricing law.
May 17 2011
This content is from: South Korea

Korea intangibles guide

By Henry An and Wonyeob Chon of Samil PwC
May 17 2011
This content is from: European Union

EUJTPF fights image of bias

The EU’s Joint Transfer Pricing Forum (JTPF) has been accused of bias because of its composition.
May 17 2011
This content is from: Argentina

OECD may detract from UN TP work

The OECD’s proposed Global Forum for transfer pricing, which will institutionalise the involvement of developing countries, may detract from the UN’s tax committee and the work it is doing for developing countries, a ...
May 16 2011
This content is from: United States

Translation is key to improving management understanding of TP

Corporate tax executives should translate chapter nine of the OECD’s Transfer Pricing Guidelines into simpler language should be translated by corporate taxpayers so their company's management can better understand t...
May 10 2011
This content is from: United States

Intangibles: What are the restructuring issues and how can they be avoided?

Panelists at the April 2011 International Bar Association, International Fiscal Association 11th Annual Tax Planning Strategies, US and Europe conference in Paris discussed a key aspect of the current OECD project on ...
May 10 2011
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Asia tells tax transparency story

The age of tax scrutiny has arrived, a practitioner told International Tax Review's Asia Tax Executives ' Forum today.
May 10 2011
This content is from: Netherlands

Why the Dutch don't like the CCCTB

The Dutch government has rejected the recent EU proposals for a Common Consolidated Corporate Tax Base (CCCTB), citing a number of key objections to the proposals including the issue of allocation keys.
May 10 2011
This content is from: South Africa

SABMiller faces scrutiny by African governments

Five African governments will convene in South Africa next month to discuss SABMiller's transfer pricing strategies in the continent.
May 05 2011
This content is from: United States

WTP Advisors acquires Michael J Flaherty
May 04 2011
This content is from: Transfer Pricing

ITAT rejects low turnover and segmented results as comparables

Taxpayers can no longer use companies with segmental results, or those with a comparatively low turnover, as a comparable for benchmarking purposes under transfer pricing provisions in India.
May 03 2011
This content is from: Pakistan

Pakistan mulls documentation requirements

The world’s attention has turned to Pakistan after the killing of Osama bin Laden, but companies will be keeping an eye on the country for different reasons as it considers introducing transfer pricing documentation r...
May 03 2011
This content is from: Ireland

Irish Revenue to audit TP this year

The Irish Revenue Commissioners has confirmed that a small number of transfer pricing audits will take place later this year.
May 03 2011
This content is from: Argentina

Argentina intangibles guide

By Daniel Rybnik of EnterPricing
May 03 2011
This content is from: Transfer Pricing

OECD aims to clarify beneficial ownership

The OECD is inviting public comment on the meaning of beneficial ownership due to the number of differing interpretations by courts and tax administrations.
May 02 2011

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