This content is from: India How taxpayers should interpret India’s new APA rules India‘s rules on advance pricing agreements (APA), which were published today, allow for the introduction of bilateral and multilateral APAs. By Sophie Ashley August 30 2012
This content is from: France How to choose branches or subsidiaries in your corporate structure A constant issue faced by multinational taxpayers is whether branches or subsidiaries are a more useful and flexible part of the corporate structure and in what circumstances it is appropriate to employ one over the o... August 29 2012
This content is from: United Kingdom HMRC £1 billion transfer pricing yield may signal fast-track APA system HM Revenue & Customs has collected more than £1 billion ($1.6 billion) in transfer pricing yield between March 2011 and 2012. Tax practitioners hope the high figure means more resources for the authority’s advance pri... By Sophie Ashley August 29 2012
This content is from: India Introduction of human intangible in transfer pricing India’s Finance Bill 2012 amended the definition of international transaction by widening the definition of intangibles, with the introduction of human capital related intangibles such as trained and organised workfor... August 27 2012
This content is from: Sponsored How APAs can help tackle tax avoidance Advanced pricing agreements (APAs) have long been hailed for the certainty they provide to taxpayers and authorities. But they can also be a useful tool in tackling avoidance with sufficient transparency. By Salman Shaheen August 27 2012
This content is from: Australia Mining for insights from transfer pricing leaders Taxpayers should not pass the opportunity to get answers from influential transfer pricing officials in September. August 23 2012
This content is from: Italy Why Italian taxpayers are turning to alternative dispute resolution Italian taxpayers are increasingly turning to alternative dispute resolution (ADR) to settle transfer pricing disputes in a trend advisers say was initiated by the recent release of guidelines clarifying the MAP process. By Joe Dalton August 22 2012
This content is from: India Treatment of forex gains and losses in transfer pricing Enterprises engaged in cross-border transactions bear forex risks and consider this when setting the prices/margins if such risks are not passed on to their counterparts. August 22 2012
This content is from: Canada Canada proposes changes to transfer pricing The Canadian Ministry of Finance has proposed a number of changes to its tax regime, including transfer pricing amendments, of particular note is the plan to treat investments in foreign affiliates by foreign-controll... By Sophie Ashley August 20 2012
This content is from: India India maintains tolerance band for transfer pricing adjustments India’s taxpayers have received welcome news from the Income Tax Department that the tolerance band for transfer pricing adjustments will remain at 5% for financial year 2011 to 2012. By Sophie Ashley August 20 2012
This content is from: United Kingdom UK HMRC makes changes to risk assessment and guidance on transfer pricing reports: ANAL... HM Revenue & Customs (HMRC) has published a major rewrite of the sections on transfer pricing in the Inland Revenue Manuals. August 16 2012
This content is from: France New Global Transfer Pricing Forum will discuss taxpayers’ practical experiences Clearly, profit allocation has become an even more critical concern for taxpayers at this time. They have to become adept at identifying the best locations for their company to locate their activities to derive the mo... August 15 2012
This content is from: Transfer Pricing How APAs can help tackle tax avoidance Advanced pricing agreements (APAs) have long been hailed for the certainty they provide to taxpayers and authorities. But they can also be a useful tool in tackling avoidance with sufficient transparency. August 15 2012
This content is from: Brazil What the modified Brazilian CUP means to taxpayers Napoleão Dagnese head of international tax at OC Oerlikon, a high-tech industrial company, provides a critical analysis of the changes to the Brazilian transfer pricing regime, from the taxpayers’ perspective. August 15 2012
This content is from: United Kingdom Significant changes to UK transfer pricing guidelines HMRC has made significant changes to the transfer pricing sections of the Inland Revenue Manuals. August 13 2012
This content is from: Finland Misreported transfer pricing losses by Finnish government shows “ignorance” of pricing ... The Finnish government moved quickly today to clarify figures released by the Parliament’s Audit Committee which stated that the Finnish exchequer lost up to $2 billion annually because of transfer mispricing. By Sophie Ashley August 08 2012
This content is from: Norway Norway transfer pricing documentation guide Hans-Martin Jørgensen and Michael Vorndran of Deloitte August 08 2012
This content is from: Malaysia Malaysia transfer pricing documentation guide By Bernice Tan of Taxand Malaysia August 07 2012
This content is from: Greece Greece transfer pricing documentation guide By Stefanos Mitsios of Ernst & Young August 07 2012
This content is from: United States What to do about infusion capital under transfer pricing audit Infusion of capital, borrowed under a corporate guarantee at an overseas location is raising considerable transfer pricing audit challenges for MNCs in India. August 07 2012
This content is from: India Rabo India Finance case: Audit cannot be reopened purely because of opinion change The Mumbai High Court has held, in the case of Rabo India Finance, that reopening audit proceedings based on a change of opinion is invalid by law. August 07 2012
This content is from: Austria Austria transfer pricing documentation guide By Andrea Lahodny and Gabriele Holzinger of Deloitte August 07 2012
This content is from: Indonesia Indonesian transfer pricing documentation guide By Permana Adi Saputra of PB Taxand August 07 2012
This content is from: The danger of non-arm’s-length management fees Management fees present particular difficulties for taxpayers. Whenever an asset management service is performed by a resident of one jurisdiction for a recipient in another there are transfer pricing implications. By ITR Correspondent August 05 2012
This content is from: Netherlands OECD recognises demand for more guidance on guarantee fees and dispute resolution in tr... Joe Andrus, head of the OECD’s transfer pricing unit, has told TPWeek that guarantee fees and credit ratings are an important issue for the OECD but it is not possible to say when a formal project on the topic might s... By Sophie Ashley August 05 2012
This content is from: Brazil Dealing with the transfer pricing peculiarities in Brazil, India and Russia Taxpayers are suffering as a result of the OECD’s lack of involvement with the world’s leading emerging economies when it comes to transfer pricing. By Jack Grocott August 05 2012
This content is from: Denmark Denmark transfer pricing documentation guide Tim Holmes and Thomas Bjerre of Ernst & Young Copenhagen outline the approach to the transfer pricing documentation requirements in Denmark. August 02 2012
This content is from: Transfer Pricing The danger of non-arm’s-length management fees Management fees present particular difficulties for taxpayers. Whenever an asset management service is performed by a resident of one jurisdiction for a recipient in another there are transfer pricing implications. By Sophie Ashley August 01 2012
