This content is from: United States IRS to release new procedures for APMA applications The IRS will release new procedures governing advance pricing agreements (APA) and mutual agreement procedure (MAP) applications received by the advance pricing and mutual agreement (APMA) programme within the coming ... By Emma Powell March 28 2013
This content is from: United States What the US bilateral safe harbour should look like The Internal Revenue Service (IRS) is inviting public comment on the development of bilateral safe harbours with US treaty partners, giving taxpayers and foreign competent authorities the opportunity to influence a sa... By Sophie Ashley March 27 2013
This content is from: United States IRS stats signal growing faith in APMA programme The IRS has released statistics on transfer pricing cases for the calendar year 2012 – the first since the formation of the joint advance pricing and mutual agreement (APMA) programme. The figures signal growing taxpa... By Emma Powell March 26 2013
This content is from: Canada Canada broadens thin capitalisation rules in 2013 budget Canada’s 2013 budget included significant changes to cross-border taxation, including the broadening of the country’s thin capitalisation rules. March 26 2013
This content is from: Italy Official bulletin on international tax ruling in Italy On March 19 2013, the Italian Revenue Office published the second edition of the International Tax Ruling Bulletin (bulletin), about three years after its first edition (April 14 2010). Piergiorgio Valente and Caterin... By ITR Correspondent March 25 2013
This content is from: United Kingdom UK holds back on introducing transfer pricing reform until G8 meeting The UK Chancellor refrained from introducing any new transfer pricing measures in his budget for 2013. However he reiterated his commitment to working at an international level to tackle base erosion and profit shifting. By Emma Powell March 21 2013
This content is from: United Kingdom HMRC confirms that transfer pricing documentation is covered by the senior accounting o... In the UK, companies or groups with turnover over £200 million ($300 million) and / or a balance sheet total over £2 billion in the preceding accounting period must appoint a senior accounting officer (SAO). By ITR Correspondent March 20 2013
This content is from: Italy Arm's-length value of royalties: Italian case law Piergiorgio Valente, managing partner of Valente Associati GEB Partners, looks at the Italian case law surrounding the arm’s-length value of royalties. By ITR Correspondent March 20 2013
This content is from: Russia Russian transfer pricing deadline may be delayed because of burdensome notification The first deadline for taxpayers in Russia to submit details of related-party transactions for 2012 may be delayed until the end of the year because of taxpayers’ concerns over the complexity of the notification requi... By Emma Powell March 19 2013
This content is from: United Kingdom GE explains how to manage your company’s tax reputation in a large multinational Multinational companies are more concerned about the image their tax affairs portray to the public than ever before but, with tax departments operating in a number of different countries, with various tax managers res... By Sophie Ashley March 19 2013
This content is from: United States Ernst & Young announces raft of tax team changes Ernst & Young has announced the appointment of six new tax partners amid a host of hires. March 18 2013
This content is from: Japan Japanese taxpayers may now be subject to joint transfer pricing and corporate tax audits Taxpayers in Japan may now have their transfer pricing included in a single corporate tax audit after the National Tax Authority clarified procedures to be taken during tax audits. By Emma Powell March 14 2013
This content is from: Denmark Danish tax authority demands $1 billion from Microsoft over undervaluing of software The Danish tax authority, SKAT, has demanded around DKK 5.8 billion ($1 billion) in back taxes from Microsoft Denmark over the sale of software rights to its Irish subsidiary, according to local reports. The case is s... By Emma Powell March 12 2013
This content is from: Transfer Pricing Tax authorities using CUPs for pricing transactions Matthew Wall and David Jarczyk explain the new trend where tax authorities use third party agreements to test, and adjust if needed, the arm’s length price of related party transactions. March 12 2013
This content is from: Finland Location savings recognised by the Finnish Supreme Administrative Court The Finnish Supreme Administrative Court (SCA) rendered a landmark decision on March 4 2013, explains Kennet Pettersson of Ernst & Young. The main dispute concerned location savings and whether such benefits could be... March 11 2013
This content is from: India India Budget 2013 special focus It is fair to say the Indian budget this month left corporate investors disappointed. Expectation was high for business-friendly tax measures but few appeared, save for an announcement that safe harbour rules and guid... By Sophie Ashley March 08 2013
This content is from: Germany Germany proposes to limit participation exemptions for hybrid instruments The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. The measure may force taxpayers to reassess the pricing of hybr... By Emma Powell March 07 2013
This content is from: China Former Chinese SAT official to boost Baker & McKenzie’s NY TP practice March 07 2013
This content is from: Denmark What taxpayers need to get straight about the OECD BEPS report Last month the OECD released a report about multinational companies’ tax planning to lower corporate tax liability to unacceptably low levels. The report acts as a first-step against the use of base erosion and profit... March 06 2013
This content is from: South Korea Korea clarifies arm’s-length calculation of intercompany guarantee transactions The Korean government has issued guidance on the calculation of the arm’s-length price of guarantee fees for intercompany-guarantee transactions in response to a growing number of disputes involving companies receivin... By Emma Powell March 05 2013
This content is from: United Kingdom How to calculate the UK patent box HM Revenue & Customs released its guidance on the new patent box regime in its Corporate Intangibles R&D Manuals (CIRD) and a series of road-shows. By ITR Correspondent March 04 2013
