This content is from: Greece Greece introduces APA system and modernises transfer pricing legislation Greece has abolished the legislative transfer pricing framework developed by the Ministry of Development. The move aims to rationalise and modernise the rules by broadening the definition of related entities and intro... By ITR Correspondent January 31 2013
This content is from: European Union How to better integrate financial systems and transfer pricing More taxpayers want better integration between their financial accounting systems and transfer pricing to give them a greater degree of compliance certainty. By Emma Powell January 31 2013
This content is from: India No clear winner in LG India marketing intangibles case: In-depth analysis The special bench of the Delhi Income Tax Appellate Tribunal (ITAT) has recently delivered a verdict on the much debated issue of marketing intangibles in the case of LG Electronics. Sanjiv Malhotra, of BMR Advisors, ... By ITR Correspondent January 30 2013
This content is from: Italy Year-end adjustments: the Italian perspective In matters of transfer pricing, the terms “compensating adjustments” and “year-end adjustments” refer to the adjustments made by companies to align the transfer pricing criteria they adopted during the fiscal year wit... By ITR Correspondent January 29 2013
This content is from: India Taxpayers say LG decision in favour of Indian Revenue is positive The LG tax ruling in India, on the transfer pricing aspects of marketing intangibles, is a shot in the arm for the Indian authorities because the Income Tax Appellate Tribunal (ITAT) deems, when the taxpayer incurs hi... By Sophie Ashley January 29 2013
This content is from: Brazil BRICS tax cooperation special focus International Tax Review provides taxpayers with in-depth analysis of developments in Brazil, Russia, India, China and South Africa (BRICS), along with the rest of the world. By Sophie Ashley January 28 2013
This content is from: Philippines Philippines issues transfer pricing regulations The Philippines Secretary of Finance has issued formal transfer pricing legislation that provides guidance on the application of the arms-length principle. By Emma Powell January 28 2013
This content is from: Brazil How BRICS can impact your transfer pricing The BRICS are steadily earning their place in international transfer pricing policy. With strong economies, investment in and out of the BRICS is constantly growing. By Sophie Ashley January 24 2013
This content is from: New Zealand New Zealand thin cap proposals will be challenging for taxpayers The New Zealand Inland Revenue has proposed changes to the country’s thin capitalisation rules that will widen their application to cover multiple controlling foreign investors. If they proceed, the measures will requ... By Emma Powell January 24 2013
This content is from: Brazil BRICS's tax authorities promise to share information The BRICS countries' (Brazil, Russia, India, China and South Africa) tax authorities have agreed to share information to strengthen their tax systems, including India helping South Africa to implement an advance prici... By Matthew Gilleard & Sophie Ashley January 23 2013
This content is from: Brazil BRICS’s tax authorities to exchange information The BRICS countries’ (Brazil, Russia, India, China and South Africa) tax authorities have agreed to exchange information to strengthen their tax systems, including India helping South Africa to implement an advance pr... By Matthew Gilleard & Sophie Ashley January 23 2013
This content is from: Austria Vienna tax competitiveness conference on balancing act of taxing multinationals Taxpayers at the Developing a Tax Environment for Growth and Competitiveness conference in Vienna last week said, striking a balance between attracting investment and bringing in revenue is difficult to achieve becaus... By Matthew Gilleard January 22 2013
This content is from: India How GE India’s tax case could affect your characterisation of R&D GE India is fighting the authorities in the Income Tax Appellate Tribunal (ITAT) over the characterisation of its transactions. The case is bringing the use of research and development (R&D) into question. By Sophie Ashley January 22 2013
This content is from: Russia Russia agrees first APA with Rosneft but taxpayers still mistrust TP regime The Russian Federal Tax Service has concluded the country’s first advance pricing agreement (APA) with state-controlled oil company, Rosneft. However some taxpayers have expressed distrust in the country’s transfer pr... By Emma Powell January 22 2013
This content is from: Austria Vienna tax competitiveness conference explains why taxing multinationals is balancing act Striking a balance between bringing in revenue and attracting investment is a key concern for tax policymakers. But, as taxpayers at the Developing a Tax Environment for Growth and Competitiveness conference in Vienna... By Matthew Gilleard January 22 2013
This content is from: Sweden Net Entertainment dispute could set a precedent for substance requirements in Sweden Net Entertainment, a Swedish-based gambling software provider, will appeal against a decision by the Swedish Tax Agency to impose additional taxes after it found the company employing erroneous transfer pricing method... By Emma Powell January 17 2013
This content is from: Brazil New Brazilian transfer pricing laws aim to cut disputes The Brazilian government has published guidance on Law 12715/12, to implement changes in the transfer pricing regulations in a bid to reduce the backlog of cases. By Sophie Ashley January 15 2013
This content is from: France Why French taxpayers should look at their financing structures after Finance Bill The French government has placed a new limitation on the deduction of financial expenses as part of a raft of measures introduced under the Finance Bill for 2013. This may force highly leveraged groups to reassess the... By Emma Powell January 15 2013
This content is from: Transfer Pricing Baker & McKenzie Mexico elects new TP partner By Sophie Ashley January 15 2013
This content is from: Direct Tax What you have missed on ITR Premium BAE Systems; Ireland US FATCA agreement; UK MP publishes FTSE100 transparency responses; Cyprus IP regime; Vietnam VAT exemptions; Play.com exits Jersey; Hong Kong Court of Appeal; Canada Revenue Agency transfer prici... By ITR Correspondent January 14 2013
This content is from: China China SAT to incorporate country UN chapter into circulars The State Administration for Taxation (SAT) is intending to incorporate the China chapter, an appendix in the UN’s transfer pricing manual, into tax circulars in an attempt to increase the amount of corporate tax it ... By Sophie Ashley January 10 2013
This content is from: United Kingdom UK House of Commons debate on corporate tax avoidance The tax avoidance debate in the UK is gaining traction. This week saw debate in the House of Commons (HoC) with a warning that the UK tax system is under serious threat in the international business environment. Paul... January 09 2013
This content is from: Malaysia Malaysia’s thin capitalisation rules delayed to protect foreign investment Malaysian thin capitalisation rules - expected last month - have been delayed to protect foreign investment in the country. By Emma Powell January 08 2013
This content is from: Brazil How Vale mining got its tax so wrong in Brazil and Switzerland Vale, one of the world’s largest mining companies, has settled tax disputes in both Brazil and Switzerland totalling $486 million, which will affect its fourth quarter profits this year. January 08 2013
This content is from: Philippines Philippine transfer pricing regulations still under review Draft revenue regulations for transfer pricing in the Philippines are still under review by the Department of Finance for final approval and issuance, despite rumours they would be published by the end of 2012. By Emma Powell January 08 2013
This content is from: United Kingdom Why HMRC could choose GAAR over transfer pricing challenge The Chancellor's Autumn Statement confirmed the introduction of a general anti-abuse rule (GAAR) in the forthcoming Finance Bill 2013 (FB 2013). January 03 2013
