Transfer Pricing

Archive: Transfer Pricing

This content is from: Transfer Pricing

TP arbitration for developing countries: Benefits and burdens

The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in ...
September 30 2013
This content is from: European Union

European Council calls for expanded disclosure requirements for non-financial and diver...

Following its May 22 meeting, the European Council issued a set of Conclusions on taxation which included a call for “rapid progress” on a number of issues including a statement that “…the proposal amending the Direct...
By ITR Correspondent
September 30 2013
This content is from: European Union

BEPS: OECD insists it is engaging with developing countries

More than 300 senior tax officials from more than 100 jurisdictions and international organisations met in Paris on September 26 and 27 to discuss solutions to unintended double non-taxation caused by base erosion and...
By Matthew Gilleard
September 30 2013
This content is from: India

Foreign employee secondments and the PE issue

Companies often second their employees to other firms in their group abroad but this can create a permanent establishment (PE) risk; something that can take up an unreasonable amount of time for a tax director if not ...
By Sophie Ashley
September 30 2013
This content is from: United States

Americas Awards winners announced

Find out who took home the awards from last week's International Tax Review ceremony in New York.
By Ralph Cunningham
September 29 2013
This content is from: Transfer Pricing

OECD lines up next transfer pricing chief after Joe Andrus

If you think you are the right person to lead the OECD’s transfer pricing unit, start dusting off your resumé and perfecting your interview technique.
September 29 2013
This content is from: United Kingdom

Compensating adjustment mechanism: Another loophole closed

The UK government is changing the compensating adjustment mechanism in its transfer pricing legislation, which will affect services companies and loans from individuals or partnerships to companies that are more than ...
By Sophie Ashley
September 25 2013
This content is from: Australia

Pascal Saint-Amans on timing and approach to the BEPS and intangibles projects

Despite the OECD’s Base Erosion and Profit Shifting (BEPS) project being much broader than the intangibles project in terms of its impact on corporate tax, the time frame for the BEPS is much shorter and there is more...
By Sophie Ashley
September 19 2013
This content is from: United States

Why it’s important to know who is on your transfer pricing audit panel

Panellists on the controversy panel at International Tax Review’s 13th Global Transfer Pricing Forum in New York this week said it is crucial to find out which IRS tax officials will be involved in your transfer prici...
By Sophie Ashley
September 19 2013
This content is from: India

Indian industry professionals and Revenue officials discuss need for collaboration

On September 13 2013, Tax Sutra, in conjunction with knowledge partner, Deloitte, organized an interactive discussion between industry professionals and Akhilesh Ranjan, Indian Competent Authority, and Kamlesh Varshne...
September 17 2013
This content is from: United States

Americas Awards 2013 shortlists for ceremony in two weeks

International Tax Review has added the final categories to the shortlists for the Americas Awards 2013, which recognise the most outstanding provision of tax services in North and South America between June 2012 and J...
September 12 2013
This content is from: Russia

Why secondment has little impact on permanent establishment in Russia

Companies that second employees to related parties in foreign jurisdictions often experience issues with permanent establishment (PE), which can take up an unreasonable amount of time for tax directors. However, In Ru...
September 11 2013
This content is from: Brazil

Global head of tax's guide to approaching secondment and PE

Jitendra Grover, global head of tax for Aricent Group, a global innovation and technology services company, warns that if a person is providing services for an entity in one country (home country) and has spent a cons...
By Sophie Ashley
September 09 2013
This content is from: Germany

Why Germany’s move to align PE rules with OECD could increase transfer pricing risk

Germany’s Federal Ministry of Finance has published draft legislative regulations for determining profits of permanent establishments (PE) using the arm’s-length standard. But advisers are concerned the legislation wi...
By Sophie Ashley
September 05 2013
This content is from: United States

Navigating BEPS with transparency and technology

Internationally coordinated efforts to update taxation rules have never been stronger. With these changes come new challenges for taxpayers. Brian Tully, vice president and head of ONESOURCE Transfer Pricing for the T...
September 04 2013
This content is from: United Kingdom

MAP becoming more popular in the UK

On September 2 2013, the OECD released its 2012 mutual agreement procedure (MAP) statistics of its member countries and of partner economies that agreed to provide such statistics.
By ITR Correspondent
September 03 2013

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