This content is from: Ireland Irish Revenue boosting its transfer pricing tool kit The Irish Revenue Commissioners are in the market for more corporate databases through which they can evaluate companies’ transfer pricing more effectively. By Sophie Ashley May 29 2013
This content is from: Spain Spanish companies increase related party borrowing as banks clamp down on lending More Spanish companies are receiving financial assistance through related party loans due to greater bank restrictions on corporate loans, advisers say. By Emma Powell May 29 2013
This content is from: Transfer Pricing First bilateral safe harbour agreements could be signed within a year The OECD has revised its guidance to governments establishing safe harbours to push countries to set up bilateral agreements. However advisers say the efficiency of the system will depend on how consistent agreed rate... By Emma Powell May 27 2013
This content is from: India India's Honda decision good news for import and export heavy industries A transfer pricing adjustment imposed on Honda’s Indian company, after fluctuations in the foreign exchange rate, has been overturned by the Delhi bench of the Income Tax Appellate Tribunal (ITAT). By Emma Powell May 22 2013
This content is from: New Zealand New Zealand companies risk losing interest deductions unless they review their non-resi... The New Zealand government has extended the scope of the thin capitalisation rules in the 2013 budget. Taxpayers will need to consider how these changes impact their debt to equity funding costs. By Emma Powell May 20 2013
This content is from: Transfer Pricing Tax Justice Network pips OECD to the post in leading TP force poll The Tax Justice Network has been voted as the leading force in global transfer pricing policy, in front of the OECD. By Sophie Ashley May 20 2013
This content is from: Transfer Pricing HMRC misses its target audience with TP briefing After the UK’s HM Revenue & Customs (HMRC) received such negative press from the Public Accounts Committee (PAC) for its approach to transfer pricing, the tax authority has released a briefing, intended to clarify its... By Sophie Ashley May 15 2013
This content is from: India Kodak India case clarifies definition of international transactions for TP A transfer pricing adjustment imposed on Kodak India, relating to its medical imaging business, has been overturned in the Mumbai bench of the Income Tax Appellate Tribunal (ITAT). The case is one of a growing number ... By Emma Powell May 15 2013
This content is from: China UN China chapter: Issues raised on contract R&D The announcement of the China Country Practices, as part of the UN Practical Manual on Transfer Pricing for Developing Countries (draft version), indicates a great leap in the transfer pricing (TP) administration of t... May 13 2013
This content is from: Australia Why the Australian budget will make taxpayers think twice about investing in the country The Australian government will reduce the thin capitalisation ratio of debt to equity as part of a raft of measures aimed at tackling base erosion and profit shifting, announced in the 2013 to 2014 budget. By Emma Powell May 13 2013
This content is from: Transfer Pricing Zambian restrictions on export-derived capital may deter foreign investment The Zambian government has introduced measures to monitor the transfer of capital derived from the import and export of goods and services. The legislation is designed to limit the transfer of capital earned from expo... By Emma Powell May 07 2013
This content is from: Transfer Pricing How the OECD is advising tax authorities to select high-risk TP cases The OECD has released draft guidelines to help tax authorities identify high-risk transfer pricing arrangements that may require further scrutiny. The guidance should help taxpayers utilise their compliance resources ... By Emma Powell May 06 2013
This content is from: United States Brian Trauman takes on global dispute resolution role at KPMG By ITR Correspondent May 01 2013
This content is from: European Union Spanish taxpayers can challenge TP adjustments on capital gains transferred within EU Unrealised capital gains transferred from a Spanish company to another EU member state will no longer be taxed after a European Court of Justice (ECJ) ruling that taxation was contrary to EU law. By Emma Powell May 01 2013