Transfer Pricing

Archive: Transfer Pricing

This content is from: Transfer Pricing

Official debate over alternative to arm’s-length principle will happen

Transfer pricing’s arm’s-length principle (ALP) has faced some tough criticism over the last two days at International Tax Review’s global transfer pricing forum in Singapore.
November 29 2012
This content is from: United States

Transfer Pricing Forum Asia 2012: Arms-length alternatives gain support

Tensions between the UN and OECD approaches to transfer pricing were revealed on the first day of the Transfer Pricing Forum Asia 2012, organised by International Tax Review and TPWeek, in Singapore today.
November 28 2012
This content is from: United States

Progress on Obama’s transfer pricing proposals to be slow despite election victory

Despite winning the election this month, progress on Barack Obama’s transfer pricing proposals is likely to be slow.
November 27 2012
This content is from: India

Indian ITAT ruling helps justify royalty payments by manufacturers to group companies

A recent ruling by India’s Income Tax Appellate Tribunal (ITAT) Mumbai bench should help to justify the payment of royalty by entities undertaking contract manufacturing, toll manufacturing or fully-fledged manufactur...
By Joe Dalton
November 22 2012
This content is from: Transfer Pricing

OECD transfer pricing meetings: Grant Thornton’s take

Grant Thornton’s Wendy Nicholls spoke about categorising intangible assets at the OECD transfer pricing drafts consultation last week. Here she provides her overall impressions of the discussion.
November 21 2012
This content is from: Japan

Morrison & Foerster acquires senior TP adviser
November 20 2012
This content is from: Transfer Pricing

How the OECD can improve its consultation process in tax policy

The OECD held a public consultation on the transfer pricing drafts it released earlier in the year last week in Paris. Some participants felt that the OECD could consider improving aspects of how the discussions took...
By Sophie Ashley
November 20 2012
This content is from: Transfer Pricing

Valuation is biggest bugbear in OECD intangibles work

The OECD public consultation on its recently released drafts on transfer pricing, by Working Party No 6, concluded last Wednesday in Paris. Delegates and speakers give their interpretation of the two-and-a-half day di...
By Sophie Ashley
November 20 2012
This content is from: United States

How you can get your operational transfer pricing right

Taxpayers may have appropriately robust long-term transfer pricing policies for their business on a global, regional and local basis. However, implementing these plans has the potential to trip-up even the most organi...
By ITR Correspondent
November 16 2012
This content is from: European Union

Brand licensing structures and challenges from a German perspective

Trademark licensing structures are increasingly important to multinational companies’ tax operations.
November 15 2012
This content is from: Transfer Pricing

Critics round on vague anti-abuse provisions in OECD intangibles draft

The OECD and business representatives explored the emphasis placed on anti-abuse provisions in the OECD’s draft on the transfer pricing aspects of intangibles today in Paris.
By Sophie Ashley
November 13 2012
This content is from: Transfer Pricing

World Tax 2013 is now live

The new edition of World Tax, International Tax Review's annual directory of leading firms around the world, is now live.
By Ralph Cunningham
November 13 2012
This content is from: Transfer Pricing

Why business wants multilateral safe harbours and why they must be optional

Working Party No 6 has been discussing the practicality of safe harbours at the public consultation on the OECD’s transfer pricing work in Paris today.
By Sophie Ashley
November 12 2012
This content is from: United Kingdom

Update on new UK CFC rules

The new UK controlled foreign company (CFC) rules are due to come into effect for accounting periods starting on or after January 1 2013. Lorna Smith and Liz Hughes of Grant Thornton UK emphasise the importance of ass...
November 08 2012
This content is from: United Kingdom

UK Public Accounts Committee (PAC) tackles HMRC’s transfer pricing

The UK Public Accounts Committee broached the subject of transfer pricing this week in its investigation about why HM Revenue & Customs (HMRC) is failing to collect enough money from foreign multinationals.
By Sophie Ashley
November 08 2012
This content is from: Brazil

Doubts of Brazilian transfer pricing method selection

Doubts are arising over the method that should be applied by the Brazilian tax authorities in the context of Law no. 9430/96.
November 08 2012
This content is from: Germany

Why the German transfer pricing audit environment is getting tough

The German tax authorities are highly active in transfer pricing policy. The introduction of the far-reaching rules on functions transfers during the past few years and the plans to integrate the authorised OECD appro...
November 06 2012
This content is from: Ecuador

How to arm yourself in Ecuador's battle against tax havens

The battle to stop the abuse of tax havens is becoming widespread. The Ecuador Tax Administration is joining the fight, using strategies such as making it impossible for companies whose shareholders are located in tax...
November 06 2012
This content is from: Transfer Pricing

International Tax Review's Global Tax 50

International Tax Review has published its Global Tax Top 50 for 2012. The list comprises the top 50 influences in international tax, with a top 10 ranking.
November 05 2012
This content is from: Chile

Chile introduces transfer pricing legislation

Chile has introduced transfer pricing legislation into its tax regime, as part of wider changes to the tax legislation.
By Sophie Ashley
November 01 2012

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