Transfer Pricing

Archive: Transfer Pricing

This content is from: Transfer Pricing

Siemens on how transfer pricing in Asia can be different

Li Ying, tax director and transfer pricing for North East Asia at Siemens, and one of the speakers at International Tax Review’s Asia Tax Forum in Singapore in May, talks about the issues that are taking up her time, ...
February 28 2013
This content is from: India

Indian safe harbour rules will be issued says Chidambaram

P Chidambaram, the Indian Finance Minister, said in his budget speech today that rules on safe harbours will be issued.
By Sophie Ashley
February 28 2013
This content is from: South Africa

South Africa limits interest deductibility on related party debt

New limits will be placed on the deductibility of interest on related party debt under the South African budget 2013, announced yesterday. However taxpayers are yet to receive clarification on the application of the a...
By Emma Powell
February 28 2013
This content is from: Transfer Pricing

Transfer pricing audit: Italian approach

Piergiorgio Valente of Valente Associati GEB Partners and Federico Vincenti of Centro Studi Internazionali GEB Partners explain how to cope with an Italian transfer pricing audit.
By ITR Correspondent
February 27 2013
This content is from: Transfer Pricing

India is still holding out for safe harbour rules in 2013 budget

Taxpayers and their advisers are hoping an amendment on safe harbour rules will be included in India’s finance budget on Thursday.
By Sophie Ashley
February 26 2013
This content is from: Transfer Pricing

HMRC is exchanging unilateral APA information with treaty partners

HMRC is exchanging the terms of its unilateral advance pricing agreements (APA) with UK tax treaty partners. The measure is part of the revenue’s drive towards greater transparency and began this month.
By Emma Powell
February 26 2013
This content is from: Transfer Pricing

BaseFirma appoints partners within its TP practice
February 26 2013
This content is from: Transfer Pricing

Australia continues to talk tough on tax transparency and BEPS

Assistant Treasurer David Bradbury has reinforced the Australian government’s stance on tax avoidance by claiming that protection of the tax base is the “most significant challenge to the world’s major advanced econom...
By Matthew Gilleard
February 26 2013
This content is from: Transfer Pricing

NERA promotes Starkov
By ITR Correspondent
February 21 2013
This content is from: France

France reassesses cooperative list of tax treaty states

The French government will reassess how effectively information is exchanged with bilateral treaty partners to reduce the loss of revenue through cross border transactions.
By Emma Powell
February 21 2013
This content is from: Russia

Taxpayers need cost-sharing law in Russia to combat shared service disputes

Taxpayers need cost-sharing provisions to be written into Russian tax legislation to combat an increased risk of dispute over the allocation of shared service costs.
By Emma Powell
February 19 2013
This content is from: Transfer Pricing

US KMPG’s Steven Harris opens transfer pricing law practice

The founder of KPMG’s US transfer pricing controversy practice has formed his own transfer pricing law practice.
February 18 2013
This content is from: Transfer Pricing

Next steps for the UN and OECD for intangible assets and profit shifting

The UN and the OECD are both working on important transfer pricing policy discussion reports and representatives from both organisations have said tax practitioners can expect significant developments in 2013.
By Sophie Ashley
February 18 2013
This content is from: Australia

Australian provisions target tax avoidance and profit shifting

Australia yesterday introduced reforms aimed at boosting the government’s ability to tackle base erosion and profit shifting, including changes to the transfer pricing regime and general anti-abuse rule (GAAR).
By Matthew Gilleard
February 14 2013
This content is from: Transfer Pricing

OECD unveils G20 report on base erosion and profit shifting

The OECD has identified transfer pricing as one of the challenges for policy makers and taxpayers as they attempt to reform how international tax rules work.
February 14 2013
This content is from: Transfer Pricing

Altus Alliance adds new members in Brazil, Russia, Switzerland and Hungary
February 13 2013
This content is from: United States

Why intangible policy discussions are giving Caterpillar’s head of tax “night terrors”

Robin Beran, chief tax officer and director for global tax and trade at Caterpillar, the machinery manufacturer, told delegates at the Tax Council Policy Institute conference on intangibles in Washington today that po...
By Sophie Ashley
February 13 2013
This content is from: Italy

Italian tax authority announcement will impact commercial distributors

Tax experts from the Italian Revenues Agency (IRA) have given an important interpretative answer about transfer pricing transactions carried out by foreign commercial distributors held by resident groups, in a recent ...
February 11 2013
This content is from: Transfer Pricing

Portuguese taxpayers need to review arm’s-length nature of cash pooling arrangements

A challenge by the Portuguese tax authorities of a multinational’s cash pooling arrangement – because the authorities felt it inappropriately used the comparable uncontrolled price (CUP) – has been denied by an arbitr...
By Joe Dalton
February 11 2013
This content is from: Transfer Pricing

SKAT stats show Denmark’s persistence in assessing IP transactions

The Danish tax authority, SKAT, has published its transfer pricing statistics, which show an increase in revenue from transfer pricing assessments, particularly through intellectual property (IP) transactions.
By Sophie Ashley
February 07 2013
This content is from: Transfer Pricing

Shell India tax dispute could lead to greater uniformity of valuation methods

Shell India will challenge a claim by the Indian tax authorities that it undervalued shares issued to a foreign subsidiary on the grounds that the order is contrary to tax regulations. If Shell is unsuccessful the out...
By Emma Powell
February 07 2013
This content is from: United Kingdom

Basel III confusion in transfer pricing creates double taxation risk

A lack of international consensus on the treatment of liquidity buffers, required under Basel III, is leaving banks exposed to the risk of double taxation.
By Emma Powell
February 07 2013
This content is from: United Kingdom

HMRC says no link between amount demanded and amount collected in transfer pricing asse...

HM Revenue & Customs (HMRC) has said it does not expect to see a link between the tax demanded and yield achieved in transfer pricing assessments and does not keep records to attempt to link them.
By Sophie Ashley
February 04 2013
This content is from: Sweden

Sweden introduces more stringent rules for deduction of interest

Nils von Koch of KPMG explains how taxpayers can deal with the stricter approach to deduction of interest in Sweden.
February 01 2013

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