This content is from: Chile Amendments to TP legislation and new informative return Roberto Carlos Rivas, Carolina Alexandres and Gabriel Bernal of PwC look at the changes to transfer pricing legislation which came into force in September last year. April 30 2013
This content is from: India Unclear tolerance bands put Indian taxpayers at greater risk of TP adjustments Indian taxpayers that import goods into the country and sell in bulk will be at greater risk of transfer pricing adjustments as the government has reduced the tolerance band for wholesale traders to 1%. Advisers have ... By Emma Powell April 29 2013
This content is from: Brazil The leading forces in global transfer pricing TPWeek is asking tax practitioners and policy observers who, or what, they think is the leading force in transfer pricing for 2013. By Sophie Ashley April 28 2013
This content is from: Netherlands Why Dutch guidance on interest deductibility of related party debt is inadequate The Dutch Ministry of Finance has released guidance on rules which limit interest on related party debt. However advisers have said taxpayers need further clarification on the deductibility of interest when purchasing... By Emma Powell April 24 2013
This content is from: United States 3M IRS TP dispute may lead to taxpayer refunds US-based conglomerate 3M has filed a petition with the US Tax Court that could overturn a regulation allowing the IRS to reallocate funds between related parties where foreign law prohibits payment. If successful, tax... By Emma Powell April 22 2013
This content is from: China SAT’s Liao Tizhong discusses China’s transfer pricing position: Part two Liao Tizhong is deputy director general of international taxation in the State Administration of Taxation (SAT) of the People’s Republic of China. He speaks to TPWeek, in a two-part interview, about China's audit focu... By Sophie Ashley April 21 2013
This content is from: Norway Norwegian interest deduction proposals could force companies to consider mergers or gro... The Norwegian Ministry of Finance has proposed rules limiting deductions on intra-group loans, which if enacted, advisers say would give Norway one of the most restrictive legislative frameworks for interest deduction... By Emma Powell April 17 2013
This content is from: Australia Why companies should adopt more flexible financing structures if Australia changes its ... Australian taxpayers may have to look again at their financing structures if the government makes changes to thin capitalisation rules in the budget on May 14. April 17 2013
This content is from: Germany Why German multilateral controls could reduce interest charges in TP disputes The German government has launched a multilateral control pilot that could combat interest charges on funds trapped in advance pricing agreements (APA) or competent authority arbitration. By Emma Powell April 15 2013
This content is from: South Africa South African thin cap rules force taxpayers to justify substance of loans The South African Revenue Service (SARS) has issued draft guidelines for the application of thin capitalisation rules, which will force taxpayers to justify the business reason for receiving a loan. However, advisers ... By Emma Powell April 10 2013
This content is from: China SAT’s Liao Tizhong emphasises China’s commitment to developing its transfer pricing regime Liao Tizhong, deputy director general of international taxation in the State Administration of Taxation (SAT) of the People’s Republic of China, has emphasised the government’s commitment to developing its transfer pr... By Sophie Ashley April 09 2013
This content is from: China SAT’s Liao Tizhong discusses China’s transfer pricing position: Part one Liao Tizhong is deputy director general of international taxation in the State Administration of Taxation (SAT) of the People’s Republic of China. He speaks to TPWeek, in two parts, about China’s stance on internation... By Sophie Ashley April 09 2013
This content is from: Australia Australian TP Bill: ongoing losses, financing structures and business restructuring at ... Taxpayers in Australia should review their transfer pricing documentation to fulfill their self-assessment obligations under a bill introduced by the Australian government. By Emma Powell April 08 2013
This content is from: Vietnam Vietnamese authorities open up about transfer pricing developments The head of Vietnam’s transfer pricing department, within the General Department of Taxation (DGT), speaks to TPWeek about developments in the country’s legislation including the status of advance pricing agreements (... By Sophie Ashley April 07 2013
This content is from: Canada Why Canadian companies conducting reinsurance transactions are having difficulties with... Companies conducting reinsurance transactions in Canada must be audit ready because the pricing of reinsurance premiums will be subject to increased scrutiny. But some taxpayers are having compliance problems. By Emma Powell April 01 2013
This content is from: European Union Shortlists announced for European Tax Awards 2013 In-house tax departments, both big and small, have more chances for recognition at International Tax Review’s European Tax Awards 2013 presentation at the Dorchester hotel in London on May 15. April 01 2013
