This content is from: United States How to price embedded intangibles in the US An embedded intangible is an element of another category of transaction, according to Rob Plunkett of Deloitte’s Washington office. August 30 2011
This content is from: Transfer Pricing SPECIAL FEATURE: How related party status is influencing football club deals Forget player transfers, it’s transfer pricing that could put Manchester City Football Club under the microscope of football’s governing body, UEFA. August 30 2011
This content is from: Transfer Pricing OECD’s new head of transfer pricing named Caroline Silberztein’s replacement as head of the OECD’s Transfer Pricing unit has been named as Joseph Andrus. August 29 2011
This content is from: United States The transfer pricing politics behind the IRS reshuffle Practitioners have said the decision to move responsibility for the US advance pricing agreement programme (APA) and mutual agreement procedure (MAP) from the Office of Chief Counsel to the IRS commissioner has as muc... August 29 2011
This content is from: Vietnam EXCLUSIVE: Vietnam will introduce APA programme An industry body has exclusively revealed to TPWeek that the Vietnamese government will introduce an advance pricing agreement (APA) programme in its tax code. August 24 2011
This content is from: France Transfer pricing research centre to open next month An international research centre will launch in the Netherlands next month to study and analyse transfer pricing issues to assist multinationals (MNE) and governments to deal more effectively with the increasing compl... August 23 2011
This content is from: Transfer Pricing EXCLUSIVE: Silberztein’s final OECD interview Caroline Silberztein is a big name in transfer pricing circles. As head of the OECD’s transfer pricing unit she has helped shape the way the world approaches and applies transfer pricing guidelines for the past 10 years. August 22 2011
This content is from: PwC US adds transfer pricing and tax controversy principal Gregory Barton has joined the firm and will be based in the Chicago office. He will operate in both the transfer pricing and tax controversy and dispute resolution practices. August 22 2011
This content is from: India Indian Revenue opportunism rules out multiple year data The case of Symantec Software Solutions Pvt Ltd, heard before the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), has implications for the application of transfer pricing provisions, which continue to differ... August 16 2011
This content is from: Estonia Estonian transfer pricing guidelines are too generic Advisers in Estonia have said the new transfer pricing guidelines, introduced by the Tax and Customs Board, are not comprehensive enough for taxpayers. August 16 2011
This content is from: Brazil Difficulties when applying the Brazilian comparable independent price (CIP) Brazil’s transfer pricing rules are predominantly outlined in Law 9430, as amended, and by the Federal Revenue Service’s Normative Instruction (NI) 243. August 14 2011
This content is from: Brazil Difficulties when applying the Brazilian comparable independent price (CIP) Brazil’s transfer pricing rules are predominantly outlined in Law 9430, as amended, and by the Federal Revenue Service’s Normative Instruction (NI) 243. August 11 2011
This content is from: Canada Global Transfer Pricing Forum 2011 is centre of debate 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. August 10 2011
This content is from: India 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... August 09 2011
This content is from: United Kingdom Vodafone says charities have approached country-by-country reporting in wrong way Vodafone is one of four companies Christian Aid is trying to convince to support country-by-country reporting with its FTSE4 campaign. August 09 2011
This content is from: Colombia Colombia intangibles guide By Carlos Mario Lafaurie Escorce of PwC Colombia August 09 2011
This content is from: Russia How Russian transfer pricing legislation could cause problems for multinationals Discrepancies between the OECD guidelines and Russia’s new transfer pricing legislation, which the president signed into law last month, could cause problems for international groups. August 09 2011
This content is from: Turkey Why Turkish APAs are not taking off Weeks after Turkey agreed its first unilateral advanced pricing agreement (APA) on July 15 and more than three years after taxpayers were eligible to apply for them, interest in APAs remains thin on the ground. August 09 2011
This content is from: Transfer Pricing Communication at OECD is problem says senior official Mary Bennett, the head of OECD’s tax treaty and transfer pricing division, said communication is a barrier to the Centre for Tax Policy and Administration improving its reputation, but steps are being taken to change ... August 08 2011
This content is from: European Union EC defends project on transfer pricing for developing countries A torrent of criticism has followed the EU’s release of a transfer pricing report on developing countries. August 02 2011
This content is from: United States Get the inside-track on the IRS’s transfer pricing strategy In a speech to business economists, Sam Maruca, who has taken on the new role as head of transfer pricing in the IRS, described his plans for the new role and the transfer pricing strategies the IRS will undertake. August 02 2011
This content is from: United States Microsoft’s transfer pricing slashes US tax bill Microsoft has taken advantage of transfer pricing to lower its effective tax rate in the US to just over half the statutory tax rate, according to its Form 10-K filing with the Securities Exchange Commission (SEC). August 02 2011
