This content is from: United States IRS undergoes transfer pricing reshuffle The IRS is moving its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes, to bring them together under the Large Business & International (LB&I) Division’s international operation. July 28 2011
This content is from: Malaysia New Malaysian TP form: what taxpayers need to do The lack of clarity in part of a new transfer pricing form issued by Malaysia’s tax authorities will create some difficulties and pitfalls for taxpayers. July 26 2011
This content is from: United States Xilinx and Veritas as precedents for IP valuation A panel at the National Association of Business Economics Transfer Pricing Symposium, near Washington this week, explored the implications of pre-existing intellectual property (IP) in the IRS’s transfer pricing cases... By Anne Szustek July 26 2011
This content is from: India Where do we stand on comparables after ITAT ruling in CRM Services? The Delhi Tribunal, in the case of CRM Services, a call centre provider, has passed a relevant ruling for captive IT enabled or business process outsourcing (BPO) service providers. July 26 2011
This content is from: Brazil Brazilian thin capitalisation rules after new regulations Thin capitalisation rules were introduced in Brazil by Executive Measure 472/09, approved by Law 12249/10, and regulated by the Federal Revenue Service Normative Instruction 1154/11 (IN RFB 1154). July 25 2011
This content is from: Indian taxpayers face challenging future Next year will herald a widescale period of change for tax in India. It will force tax directors from domestic and international companies to completely reconsider their strategies and to seek efficiencies at all leve... By ITR Correspondent July 25 2011
This content is from: Thailand Thailand intangibles guide By Peerapat Poshyanonda and Alisa Arechawapongsawat of PwC Thailand July 25 2011
This content is from: Malaysia Malaysia intangibles guide By SM Thanneermalai and Anushia Soosaipillai of PwC Malaysia July 24 2011
This content is from: Uruguay Uruguay intangibles guide By Sergio Franco and María José Santos of PwC July 24 2011
This content is from: Transfer Pricing African officials deal with transfer pricing The African Tax Administration Forum’s (ATAF) first general assembly in Mauritius next week will focus on illicit financial flows, tax evasion and tax avoidance. July 20 2011
This content is from: Vietnam FREE: Vietnam revenue pledges to focus on transfer pricing deceptions The Ho Chi Minh City Tax Department in Vietnam has promised to investigate global companies who claim to make consistent losses in the country. July 19 2011
This content is from: Turkey Turkey makes mark with first APA Turkey hopes to move on to negotiating bilateral advance pricing agreements after the signing of its first unilateral APA last week. July 19 2011
This content is from: Japan Japan: Out with hierarchy and in with most appropriate method Japan’s transfer pricing legislation was revised on June 30 2011 to introduce the most appropriate method rule, rather than the hierarchy system, which is now abolished. July 19 2011
This content is from: Transfer Pricing Dominican Republic’s transfer pricing almost aligned with OECD The Dominican Republic’s tax authority, Direccion General de Impuestos Internos (DGII), is implementing new documentation requirements on transfer pricing, effective fiscal year 2011. July 19 2011
This content is from: Russia Russian Parliament accepts new transfer pricing legislation After years of delay, the Russian parliament has finally passed the new transfer pricing rules, though there have been significant amendments. By Salman Shaheen July 19 2011
This content is from: Transfer Pricing Bangladesh to crack down on transfer mispricing following UN report Bangladesh’s National Board of Revenue intends to check irregular transfers of funds in a bid to reduce the estimated $35 billion revenue loss attributed to transfer pricing. July 19 2011
This content is from: Transfer Pricing FREE: Finding the facts specific to transfer pricing The economic recession has a lot to answer for. But, it is also the reason why transfer pricing has become a pressing issue for taxpayers everywhere. July 19 2011
This content is from: China Taxpayers urged to conduct appraisals when transferring equity interests in China Taxpayers in China transferring equity interests in Chinese companies are being advised to conduct appraisals to determine the fair market value of the transferred interest. By Jack Grocott July 12 2011
This content is from: Australia ATO signals focus on offshore profit shifting The Australian Taxation Office (ATO) is targeting foreign companies that shift profits offshore to reduce their local tax liability. The application of transfer pricing rules will be reviewed. By Matthew Gilleard July 12 2011
This content is from: United Kingdom Deloitte promotes new UK transfer pricing partner Deloitte's new partner is based outside London. July 12 2011
This content is from: Transfer Pricing Comments on OECD report focus on safe harbours The OECD received 22 different contributions from advisers concerning its June 10 report “Multi-country Analysis of Existing Transfer Pricing Simplification Measures”. July 12 2011
This content is from: United Kingdom Report calls for greater tax transparency in financial disclosure A report released this week by the Oxford University Centre for Business Taxation (CBT), commissioned by the OECD Informal Task Force on Tax and Development, has called for new transparency measures in disclosing tax ... July 12 2011
This content is from: United States FREE: Senate Bill cracks down on offshore activities US Senator Carl Levin at a July 12 press conference presented a revised version of his 2009 Stop Tax Haven Abuse Act. July 12 2011
This content is from: Italy Italy issues guidance for obtaining protection from transfer pricing penalties The Italian tax authorities have released guidelines on accessing the transfer pricing penalty protection regime. The transfer pricing rules themselves remain unaffected, but the guidelines clarify the procedure for a... By Matthew Gilleard July 10 2011
This content is from: Netherlands Transfer Pricing Associates appoints new partner Rudolf Sinx has become a global partner of the TPA Global Group. July 07 2011
This content is from: China Chinese adjustment highlights value of comparables Taxpayers need to examine and evaluate the comparable studies they plan to use in China after a transfer pricing adjustment grabbed the headlines. By Jack Grocott July 06 2011
This content is from: Australia Australia clarifies rules on transfer pricing for business restructurings In a new ruling, the Australian Tax Office (ATO) has set out how it expects business structuring for multinational enterprises to be documented for transfer pricing purposes. By Salman Shaheen July 05 2011
This content is from: United States Enter now for the Americas Awards 2011 International Tax Review will present its sixth annual Americas Awards at the Waldorf-Astoria Hotel in New York on Tuesday September 27. Now is your chance to enter. July 05 2011
This content is from: United States Congress tries to help administration define intangibles The Joint Committee on Taxation, the group consisting of members of both houses of the US Congress, laid out its plan for tackling the definition of transfer pricing intangibles in its June 14 report on the Obama admi... July 05 2011
This content is from: Transfer Pricing Inaugural Women in Business Law Awards: winners announced July 05 2011
This content is from: France Notion of relevant market remains key to French transfer pricing Taxpayers in France should be aware that they still need to justify their choice of comparables, even if the authorities have limited scope to make adjustments in this area, explain Jean-Luc Trucchi and Edouard Berthe... July 05 2011
