This content is from: Transfer Pricing Mexican revenue reveals more transfer pricing guidance on the way The Mexican Revenue Authority has confirmed it intends to release more transfer pricing guidance for taxpayers in 2012, but a specific date has not been confirmed. By Sophie Ashley November 29 2011
This content is from: European Union How the UN will use arbitration to improve MAP The UN Subcommittee on Dispute Resolution has released a report identifying three options for how arbitration can be used as an additional mechanism for mutual agreement procedures. November 29 2011
This content is from: Indonesia Petra Foods expects victory against Indonesian authorities Petra Foods, an Indonesian taxpayer, has referred to previous payments for a transfer pricing adjustment as recoverable in its third-quarter 2011 statement, meaning it expects to win its dispute with the Indonesian Ta... November 24 2011
This content is from: United States Choosing the profit level indicator in transfer pricing In transfer pricing, the main problem for practitioners is to choose which method they will use to calculate an arm’s-length price. They must also decide which profit level indicator (PLI) they will select to support ... November 23 2011
This content is from: Japan Takeda Pharmaceuticals announces Japan MAP failure Takeda Pharmaceuticals has announced that its mutual agreement procedure (MAP) with the National Tax Agency in Japan did not result in an agreement with the US. November 22 2011
This content is from: Poland Why Polish taxpayers are not using the APA programme Taxpayers in Poland are not taking advantage of the country’s advance pricing agreement (APA) regime because of the length of time it takes to complete an application, statistics reveal. November 21 2011
This content is from: Transfer Pricing OECD take note: What business really thinks about the progress of the intangibles project Intangible property is an important income generator for many multinational enterprises (MNE), so the OECD consultation with business on the transfer pricing aspects of intangibles was well attended. But, not all taxp... November 16 2011
This content is from: Germany Ghana and Germany to team up on transfer pricing Ghana is moving towards implementing a transfer pricing regime with the help of a German development agency. November 16 2011
This content is from: European Union EU JTPF to focus on cost sharing The EU Joint Transfer Pricing Forum (JTPF) will focus on cost sharing agreements (CCA) in service arrangements. Intangible assets, however, will be left out of the discussions. November 15 2011
This content is from: India Indian Revenue speaks out on record $8.9 billion adjustments This year’s final figure of Rs44,500 crore ($8.9 billion) for transfer pricing adjustments in India is more than double last year’s total. November 14 2011
This content is from: Transfer Pricing Why BIAC wants more involvement in OECD’s intangibles project The business advisory body to the OECD (BIAC) is asking for more involvement in the OECD’s drafting of guidelines for the transfer pricing aspects of intangible assets. Read a full transcript of the BIAC tax and fisca... November 10 2011
This content is from: Transfer Pricing OECD delegates given overnight assignment Before delegates left the OECD’s transfer pricing aspects of intangibles meeting on Monday night, they were asked a number of questions for overnight deliberation by Joseph Andrus, the new head of transfer pricing at ... By Sophie Ashley November 08 2011
This content is from: India Synergies cannot be taxed, says business The OECD’s Working Party No 6 meeting on the transfer pricing aspects of intangibles brought the aspect of synergies into discussion. By Sophie Ashley November 08 2011
This content is from: Transfer Pricing How goodwill is valued in distribution The concept of goodwill in the transfer pricing of intangible assets was discussed by delegates at the OECD’s Working Party No 6 meeting last week. By Sophie Ashley November 08 2011
This content is from: Transfer Pricing BIAC opens latest OECD intangible assets discussion This week’s OECD meeting with business representatives to discuss the transfer pricing aspects of intangibles began with a summary of the project so far. By Sophie Ashley November 08 2011
This content is from: United Kingdom UK Supreme Court dashes taxpayers’ hopes on thin cap but there is an alternative The second refusal of the UK Supreme Court to refer the Thin Cap GLO to the ECJ has been described as “inconsistent” and “wrong” and will end up costing taxpayers a lot of money if they decide to persist with the liti... By Jack Grocott November 07 2011
This content is from: Canada The McKesson case: Further debate on key transfer pricing principles Danny Beeton and Rupert Macey-Dare, of Freshfields Bruckhaus Deringer’s London office, analyse the technicalities of the latest Canadian transfer pricing dispute. November 04 2011
This content is from: Transfer Pricing Gazprom may consider APA since exemption from transfer pricing rules is unlikely Gazprom, one of the world’s biggest energy producers, is rumoured to have applied for an advance pricing agreement (APA) with the Russian tax authorities, after requests to be excluded from the new transfer pricing re... November 04 2011
This content is from: Australia Australian government to reform transfer pricing in response to SNF litigation Australia has released a consultation paper aiming to bring its transfer pricing regulations more in-line with international best practice, following the Revenue’s defeat in the SNF case earlier this year. November 03 2011
This content is from: United States IRS commissioner explains benefits of transfer pricing reshuffle The commissioner for large business at the IRS has explained the benefits of the recent transfer pricing reshuffle within the IRS. November 02 2011
This content is from: India India to tax guarantee fees: outbound acquisitions under threat The Indian government has said guarantee fees, paid by Indian companies in the acquisition of foreign assets, fall into the income tax net because they are a cost to the company. November 02 2011
This content is from: United States How McKesson case will test the reality of arm’s-length in accounts receivable The Tax Court of Canada has begun hearing another transfer pricing case. November 01 2011
This content is from: What Republicans want in new US tax system US corporations are fully behind the principles in a discussion draft from members of the House Ways and Means Committee on moving to a territorial tax system, if early reaction is a good guide. By Ralph Cunningham November 01 2011
