This content is from: European Union Technology firms discuss dealing with large TP adjustments and a Eurozone Armageddon As the economic situation in Europe remains uncertain, taxpayers are facing increasing numbers of audits from revenue-hungry authorities. Coupled with a potential break-up of the currency, it is important that taxpaye... By Sophie Ashley May 31 2012
This content is from: India What the Indian Authority on Advance Rulings thinks of cost contribution arrangements A case concerning cost contribution agreements in a foreign company provides insight into how they should be structured for Indian taxation purposes. May 31 2012
This content is from: Denmark Danish authorities threaten taxpayers with increased risk of penalties Foreign multinationals operating in Denmark need to review their transfer pricing arrangements, apply for advance pricing agreements (APAs) and ensure they can explain any losses filed, in response to a government Bil... By Joe Dalton May 30 2012
This content is from: Transfer Pricing Technology firms highlight risks in European transfer pricing strategies The tax environment in Europe requires different transfer pricing strategies from other global regions. Two tax executives, including the European head of tax for Siemens, the German multinational, talk to TPWeek ab... By Sophie Ashley May 30 2012
This content is from: Australia Google’s tax bill sparks Australian squeeze on tech firms, which is reminiscent of MRRT... Australia is looking to the technology industry’s transfer pricing arrangements in its fight to keep revenue within its borders but critics say its focus could be a double-edged sword if it discourages technology firm... By Sophie Ashley May 28 2012
This content is from: India Amendment to income tax regulations in India means taxpayers can use any method to just... An amendment to the Income Tax Law in India means taxpayers can use any method to justify their transfer pricing arrangements, which demonstrates a significant relaxation in the authorities’ approach. By Sophie Ashley May 24 2012
This content is from: India Mukherjee's White Paper on black money in India focuses on transfer pricing Pranab Mukherjee, India's Minister of Finance, has blamed transfer pricing and tax havens for the amount of black money flowing away from India. By Sophie Ashley May 22 2012
This content is from: United States Tax directors discuss APA experiences Tax directors from 25 different multinational companies in seven countries have shared their experiences with advance pricing agreements (APA). By Sophie Ashley May 20 2012
This content is from: Chile Incoming transfer pricing regulations in Chile The Chilean government sent a tax reform proposal to Congress on April 30 to generate additional revenues and increase expenditures in social development programmes such education, employment, economic growth and the... May 17 2012
This content is from: India Nokia adjustment case sent back to the TPO in controversial move by court The Indian Nokia case, concerning transfer pricing adjustments on excessive marketing spends, has been remanded back to the transfer pricing officer (TPO) in light of the retrospective changes in the Finance Bill. May 17 2012
This content is from: Australia Why Australia’s about-turn on permanent establishment policy means further uncertainty Despite the Australian authorities promoting the separate entity approach during the OECD’s project on permanent establishments (PE), the Treasury now looks to be doing an about-turn in favour of the single entity app... May 16 2012
This content is from: Malaysia Malaysia’s income tax and transfer pricing rules are retrospective Taxpayers in Malaysia must ensure their transfer pricing is backed-up by contemporaneous documentation after the country retrospectively amended its transfer pricing regulations. By Sophie Ashley May 16 2012
This content is from: Australia Why transfer pricing is on the up in Asia Transfer pricing was a recurring concern for taxpayers attending the International Tax Review Asia Tax Forum in Singapore last week, emerging from every panel. By Sophie Ashley May 14 2012
This content is from: South Africa South Africa’s Magashula to hammer construction industry on tax avoidance Oupa Magashula, the commissioner for the South African Revenue Service (SARS) has said they are discovering an increasing number of tax avoidance schemes through cross-border structuring, particularly by the construct... By Sophie Ashley May 14 2012
This content is from: Japan Asia reacts to the arm’s-length principle Asia is seen as less tolerant of the OECD's thinking on transfer pricing, compared to Europe and the Americas, but the region’s acceptance of the arm’s-length principle (ALP) is growing, say speakers at International ... By Sophie Ashley May 08 2012
This content is from: United States Why US taxpayers should take confidence from Microsoft ruling Microsoft’s recent US transfer pricing victory should force states to rethink the practice of outsourcing transfer pricing assessments, say advisers. By Joe Dalton May 07 2012
This content is from: United Kingdom UK revises claims for group loss relief HM Revenue and Customs (HMRC) has recently revised the guidance in its manuals regarding revisions to claims for UK group loss relief following mutual agreement procedure (MAP) settlements. May 03 2012
This content is from: India Indian government names members of international tax and TP board The Indian Ministry of Finance has set up an advisory group for international taxation and transfer pricing to reduce litigation and bring certainty for taxpayers operating in India. By Sophie Ashley May 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 May 02 2012
This content is from: Transfer Pricing Third party audit firms mean more litigation for taxpayers US states are employing third party audit firms to conduct transfer pricing assessments on a contingency fee basis, which is leading to more aggressive audits, and companies must devote more resources to state documen... By Joe Dalton May 02 2012
This content is from: Transfer Pricing Guatemala latest developing country to pass transfer pricing legislation Guatemala has passed transfer pricing legislation which will start in 2013. The rules will adhere, generally, to the OECD transfer pricing guidelines. By Sophie Ashley May 02 2012
