Transfer Pricing

Archive: Transfer Pricing

This content is from: Belgium

How the tax market thinks the BEPS Action Plan will impact transfer pricing

The OECD’s Action Plan for tackling base erosion and profit shifting (BEPS) was unveiled on July 19 at the G20 meeting of finance ministers in Moscow. The plan discusses a timeframe of between 12 and 24 months for imp...
By Sophie Ashley
August 28 2013
This content is from: India

BMW India's case - Blessing in disguise for Indian taxpayers undertaking marketing acti...

Vatika Bhatnagar, in the global transfer pricing team at Airtel India, discusses, in a personal capacity, what the BMW India ruling means for taxpayers.
August 22 2013
This content is from: United States

Indian ITAT: Assignment of contract is international transaction subject to transfer pr...

The Income Tax Appellate Tribunal’s (ITAT) judgment in the Tellabs India case will be useful guidance for determining the applicability of the transfer pricing regulations in the context of assignment versus novation ...
August 21 2013
This content is from: India

Why India’s draft safe harbour rules may need work before gaining popularity with taxpa...

The Indian Central Board of Direct Taxes has issued draft safe harbour rules that provide taxpayers with a margin under which their transfer prices would be automatically accepted by the tax authorities. However the s...
By Emma Powell
August 14 2013
This content is from: India

General Motors case reinforces Indian taxpayers’ right to use foreign entities as teste...

In the first case to reference the UN manual since the Indian government formally adopted it, taxpayers can be more confident about using a foreign entity to test whether a transaction is at arm’s-length, after the Ah...
By Emma Powell
August 12 2013
This content is from: United States

Brazil issues further guidance on interest

On August 2 2013, the Brazilian Ministry of Finance issued ordinance 427/2013, which finally provides the interest rate spread that was mentioned, but not specified, in Law 12.766/2012.
By ITR Correspondent
August 08 2013
This content is from: United Kingdom

How transfer pricing adjustments can impact indirect tax payments

Taxpayers must be more aware of the impact transfer pricing adjustments are having on their indirect tax liabilities, advisers have said. Taking an internal approach can help taxpayers reduce the number of transfer pr...
By Emma Powell
August 07 2013
This content is from: Transfer Pricing

Americas Awards 2013 shortlists announced

The shortlists for the International Tax Review Americas Awards 2013 have been released featuring the most outstanding provision of tax services in North and South America between June 2012 and June 2013.
By Sophie Ashley
August 06 2013
This content is from: Transfer Pricing

Experienced taxpayers discuss difficult transfer pricing issues

Renowned tax and transfer pricing professionals from industry, including Caterpillar, Nissan Europe, The Dow Chemical Company, Hewlett-Packard, Dell, Alstom, Lexmark International and Brown-Forman, along with official...
By Sophie Ashley
August 06 2013
This content is from: Transfer Pricing

How taxpayers can identify comparables in developing markets

Taxpayers in developing markets can find it difficult to find reliable comparables to benchmark their transfer pricing. However, the UN Practical Manual on Transfer Pricing for Developing Countries demonstrates why de...
By Emma Powell
August 06 2013
This content is from: Direct Tax

Leading industry professionals share their experience on difficult transfer pricing issues

Leading transfer pricing professionals from industry including Caterpillar, Nissan Europe, The Dow Chemical Company, Hewlett-Packard, Dell, Alstom, Lexmark International and Brown-Forman, along with officials from the...
By Sophie Ashley
August 04 2013

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