This content is from: Australia Transfer pricing is getting more technical in Asia Transfer pricing regimes in Asia are developing quickly. With India’s advance pricing agreement programme, a growing culture for dispute in China and changes to Indonesia’s legislation, to name but a few recent develo... By Sophie Ashley June 26 2013
This content is from: Italy Burden of proof in transfer pricing: Recent case law A few decisions taken in recent years by the Italian Courts have shed some light on the allocation of the burden of proof in transfer pricing disputes. Piergiorgio Valente, Managing Partner of Valente Associati GEB Pa... By ITR Correspondent June 26 2013
This content is from: South Africa Why South Africa’s request for TP information from the UK, US and Australia is unlikely... The South African Revenue Service (SARS) has approached the UK, US and Australia to obtain information relating to erroneous transfer pricing through complex offshore structures. By Emma Powell June 24 2013
This content is from: European Union How stress tests could increase related party lending Taxpayers should be watchful of the results of the European Central Bank’s (ECB) stress tests, which could increase amounts of capital transferred between related party banks. By Emma Powell June 19 2013
This content is from: Denmark Novo Nordisk battling $3.9 billion TP adjustment on transfer of biopharmaceutical division Denmark's largest listed company, Novo Nordisk, has been hit with transfer pricing adjustments of DKK 22 billion ($3.95 billion) by the Danish tax authority (SKAT) resulting in an increased tax bill of DKK 5.5 billion. By Joe Dalton June 18 2013
This content is from: Transfer Pricing Taxpayers should design a TP policy to bridge different practices of OECD and developin... Differences in guidance given by the UN and OECD transfer pricing manuals are putting taxpayers at risk of double taxation. Taxpayers should design a transfer pricing policy that acknowledges both sets of principles. By Emma Powell June 17 2013
This content is from: India Shome on appropriateness of retrospective approach to tax policy Parthasarathi Shome, minister of state to the Indian finance minister, has said there are instances where retrospective approaches, by tax authorities, are inappropriate. He was speaking at an international tax confer... By Sophie Ashley June 17 2013
This content is from: Poland Poland proposes abolishing APA annulment confidentiality Poland’s Ministry of Finance has proposed changes to the country’s advance pricing agreement (APA) regime after reviewing the effectiveness of the programme over the past six years. However, if implemented, some propo... By Emma Powell June 12 2013
This content is from: France How French taxpayers should prepare for a tougher TP regime The French Ministry of Finance has proposed tightening the country’s transfer pricing regulation and setting tougher penalties for taxpayers who fail to comply. Advisers say the recommendations are likely to be includ... By Emma Powell June 10 2013
This content is from: India Indian taxpayers must be cautious in TP reporting despite Vijai Electricals judgment Multinationals in India must maintain caution in their transfer pricing reporting of transactions involving investment into foreign subsidiaries even though the Hyderabad Income Tax Appellate Tribunal (ITAT) said tran... By Joe Dalton June 05 2013
This content is from: Japan Japanese arm’s-length range amendments may reduce TP adjustments The Japanese government has introduced a range of acceptable arm’s-length prices as part of a number of measures to amend the country’s transfer pricing rules. The change is likely to reduce the number of taxpayers su... By Emma Powell June 05 2013
This content is from: India Why India is at a critical stage in tax policy development - India Tax Forum 2013 The Indian economy grew by 5% in 2012. Outstanding by any other country’s standards, except China’s, but not enough as an annual rate if it wants to create prosperity for all of its more than 1 billion citizens. By Ralph Cunningham June 05 2013
This content is from: Transfer Pricing Your chance to speak about your BEPS concerns International Tax Review and TPWeek’s 13th Annual Global Transfer Pricing Forum will be held on September 18 and 19 at the Crowne Plaza in Times Square, New York, in association with Deloitte. June 04 2013
This content is from: India Shell India’s impact on corporates: Issuing shares to overseas parents at an alleged d... The latest transfer pricing controversy to hit unlisted (closely held) Indian corporates is the attempt by the taxman to compute a higher arm’s-length price (ALP), in respect of the shares issued by them to their o... June 04 2013
This content is from: Italy Why Indian taxpayers need more clarity on making related party loans using foreign curr... The Indian revenue authority will appeal a decision by the Mumbai Income Tax Appellate Tribunal (ITAT), involving auto manufacturer Mahindra & Mahindra, which found the Libor rate could be used when making foreign cur... By Emma Powell June 03 2013
This content is from: Italy Italian regional production tax and its impact on taxpayers IRAP is a regional production tax (established by Legislative Decree No. 446 of 15 December 1997, called IRAP Decree) levied on independent and regularly exercised activities of production or exchange of goods and/or ... By ITR Correspondent June 02 2013
