Transfer Pricing

Archive: Transfer Pricing

This content is from: Transfer Pricing

Drive for transparency is doomed, says SAB Miller

SAB Miller told ministers at the UK’s International Development Committee (IDC) that capacity building is essential if developing countries are to collect the right amount of tax but the “transparency drive to achieve...
By Sophie Ashley
April 30 2012
This content is from: Norway

How Zambian mining companies are undervaluing minerals

Mining companies in Zambia are still able to limit their taxable profits in the country, despite transfer pricing legislation, through undervaluing metals and minerals that are not traded on the global market.
By Sophie Ashley
April 30 2012
This content is from: Russia

Why Russia's guidance on controlled transactions is a headache

Russia's Ministry of Finance has clarified how taxpayers should calculate the threshold for controlled transactions, but its interpretation leaves companies with a choice of non-compliance or dedicating more resources...
By Joe Dalton
April 25 2012
This content is from: Australia

Multinationals blamed for largest proportion of Australia’s black economy

Researchers from Australia’s RMIT University have blamed multinational companies for the largest proportion of Australia’s tax leakage through their transfer pricing operations.
By Sophie Ashley
April 24 2012
This content is from: Transfer Pricing

Why controversy is inevitable for OECD when discussing arm’s-length principle

Globally recognised as the best way to control companies’ transfer pricing between related-entities; opposition to the arm’s-length principle (ALP) is growing.
By Sophie Ashley
April 23 2012
This content is from: China

How to include your CFO in your transfer pricing plan

Multinational companies say transfer pricing is their greatest concern in international tax so it is important for the head of tax to communicate with the company’s chief financial officer (CFO) and higher management ...
By Sophie Ashley
April 23 2012
This content is from: United States

Transfer pricing on BRICS' agenda at IMF and World Bank meetings next week

The theme of this week's IMF and World Bank Spring Meetings is closing the gap (including financial, gender and jobs, etcetera) so tax and transfer pricing are expected to come up during the discussions between the 13...
By Sophie Ashley
April 18 2012
This content is from: United States

IRS APA stats suggest taxpayers' lack of faith

The IRS has released its advance pricing agreement (APA) programme statistics for last year and the figures suggest taxpayers are losing patience and faith in the system.
By Sophie Ashley
April 18 2012
This content is from: India

India rules officers cannot disallow royalty based on incurred losses

The Delhi High Court has ruled that the transfer pricing officer (TPO) cannot disallow royalties just because the company paying them is incurring losses.
By Sophie Ashley
April 16 2012
This content is from: Brazil

Foundation of Brazilian transfer pricing rules changed

Brazil has introduced measures that affect the country's fundamental transfer pricing regulations.
April 15 2012
This content is from: Taiwan

Taiwan Supreme Administrative Court provides first TP ruling

Taiwan’s Supreme Administrative Court has issued a ruling in a transfer pricing case for the first time. The litigation, which focused on adjustments, went in favour of the tax authorities.
By Sophie Ashley
April 11 2012
This content is from: Direct Tax

Shortlists for European Tax Awards 2012 announced

The number of firms in contention for International Tax Review’s European Tax Awards shows that the competition for the money tax executives have to spend on external advisers is intense.
April 11 2012
This content is from: Germany

Companies must use German PEs for business restructuring before law change

Germany is amending its transfer pricing laws so transactions between permanent establishments (PEs) will be treated the same as those between subsidiaries, leading to exit taxes on the transfer of functions.
By Joe Dalton
April 10 2012
This content is from: India

India’s officials given enhanced powers to audit international transactions

A measure introduced in last month’s Finance Bill will enhance the powers of transfer pricing officers (TPOs) to audit international transactions which have not been referred by assessing officers (AOs), possibly beca...
By Joe Dalton
April 09 2012
This content is from: South Africa

SARS to invest more in transfer pricing training

The South African Revenue Service (SARS) has announced a renewed focus on transfer pricing, which will include investment in training for its staff.
By Sophie Ashley
April 09 2012
This content is from: Canada

Canada’s budget could set global revenue trend

The Canadian government has proposed changes to section 247 of the Income Tax Act in relation to transactions with foreign related parties, which could have a knock-on effect on companies’ structures involving withhol...
By Sophie Ashley
April 04 2012
This content is from: Hong Kong SAR

Procedure for seeking APA in Hong Kong

On 29 March 2012, the Hong Kong Inland Revenue Department (IRD) released the Departmental Interpretation Practice Note (DIPN) 48, Advance Pricing Arrangement (APA), establishing the procedure for enterprises seeking A...
April 03 2012
This content is from: Transfer Pricing

Why there is no short answer to the viability of the arm’s-length principle

Is the arm’s-length principle enough? The short answer is not quite, but when you put multinational companies, tax campaigners, OECD officials and economists in the same room, there is never a short answer.
By Sophie Ashley
April 02 2012
This content is from: Direct Tax

The importance of research when looking for tax advice

Hiring the right external advisers can be one of the most difficult jobs for a tax department.
April 01 2012

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