Transfer Pricing

Archive: Transfer Pricing

This content is from: Brazil

OECD and UN drafts add to taxpayers’ reading list

Tis the season for tax policy. The OECD and the UN have been busy drafting reports on tax and transfer pricing, all of which have been released this month.
By Sophie Ashley
October 30 2012
This content is from: China

Japan-China supply chain efficiency valuation and transfer pricing

Effective tax rate (ETR) planning is critical for all multinational enterprises. From a business flow standpoint, supply chain efficiency is critical.
October 30 2012
This content is from: European Union

EU JTPF needs agreement from business members today

The EU Joint Transfer Pricing Forum is meeting today to discuss issues which will need to be agreed upon by business members.
By Sophie Ashley
October 23 2012
This content is from: Brazil

How to interpret the new Brazilian transfer pricing rules

The substantial changes to the Brazilian transfer pricing regime also bring with them discrepancies between the law and the executive measure released by the revenue authority.
October 22 2012
This content is from: Canada

GSK Canada Supreme Court decision analysis

The SC dismissed the appeal by the Canada Revenue Agency (CRA) of a ruling by the Federal Court concerning the deductibility of the price paid by GSK Canada to a Swiss related-entity. The CRA said the payment was not ...
By Sophie Ashley
October 18 2012
This content is from: Canada

Canadian Supreme Court decision on GlaxoSmithKline’s transfer pricing

The Canadian Supreme Court (SC) has today delivered its first transfer pricing decision, in a case involving GlaxoSmithKline (GSK).
By Sophie Ashley
October 17 2012
This content is from: Transfer Pricing

Clear rules and concrete guidance on permanent establishment issues prove elusive

The OECD is likely to be stuck with the “least worst” definition of a permanent establishment in its model income tax treaty, a panel of leading experts conceded.
October 17 2012
This content is from: United Kingdom

Taxand appoints new global head of TP
October 16 2012
This content is from: Canada

Altus Alliance adds new members in Canada and Kenya
October 16 2012
This content is from: United States

Silicon Valley must prepare defence against IRS attack

Silicon Valley taxpayers face significant risk of attack by the Inland Revenue Service (IRS) in the US over their transfer pricing operations.
By Sophie Ashley
October 15 2012
This content is from: United States

IP Structuring: Tax planning ideas for intangible assets

Intangible assets are crucial sources of value and are of increasing strategic importance to companies.
October 15 2012
This content is from: United States

UN Tax Committee prepares to consider transfer pricing manual

As the UN Tax Committee convenes in Geneva for meetings next week, a group representing US multinational companies has called on the committee to organise a public consultation before it finalises its transfer pricing...
October 10 2012
This content is from: European Union

EU JTPF report finds common ground on cost contribution arrangements

Cost contribution arrangements (CCAs) have been treated with suspicion by both taxpayers and authorities. But an EU Joint Transfer Pricing Forum (JTPF) report seeks to help the two parties find common ground on servic...
By Salman Shaheen
October 08 2012
This content is from: United States

ABA wants more IRS guidance on related-party guarantees

The Section of Taxation of the American Bar Association (ABA) has written to IRS Commissioner Doug Shulman with recommendations for guidance on the transfer pricing of related-party guarantees.
By Matthew Gilleard
October 03 2012
This content is from: France

Dell case shows Spanish taxpayers must tread carefully over PEs

A ruling by the Spanish Central Economic-Administrative Court (TEAC) against computer technology company Dell has narrowed the possibility for groups operating in Spain to declare they have no permanent establishment ...
By Joe Dalton
October 03 2012
This content is from: United States

What the US Senate heard about offshore profit shifting

The Senate examined the shifting of profits offshore by US multinational corporations (MNCs) at a hearing on “Offshore Profit Shifting and the US Tax Code” on September 20.
By ITR Correspondent
October 03 2012
This content is from: Transfer Pricing

UN tax committee publishes draft transfer pricing manual

The UN Committee of Experts on International Cooperation in Tax Matters will consider its draft Transfer Pricing Manual for Developing Countries at its eighth session in Geneva from October 15-19.
October 02 2012
This content is from: United States

Pace comes back to KPMG
October 02 2012
This content is from: United States

Management fees: why clear contractual terms are the answer

The definition of management fees varies substantially around the world and that is leading to tax authorities mounting more and more challenges to what companies believe they are entitled to deduct from their taxable...
By Ralph Cunningham
October 01 2012
This content is from: European Union

Why Europe's arbitration convention needs a boost

Transfer pricing resources are not being spent efficiently, said a panellist at International Tax Review’s Global Transfer Pricing Forum today. Tax disputes are increasing in number and compliance requirements are mor...
By Sophie Ashley
October 01 2012
This content is from: United States

Why TP disputes are moving away from the courts

Taxpayers, revenue authorities and the courts are seeing increasing numbers of transfer pricing disputes being settled earlier, avoiding court hearings, a panel at International Tax Review’s Global Transfer Pricing Fo...
By Joe Dalton
October 01 2012
This content is from: Germany

Expected changes in German transfer pricing regulations

Changes and further regulation in relevant areas of transfer pricing expected in 2013 require taxpayers to revisit their transfer pricing model.
By ITR Correspondent
October 01 2012

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