This content is from: Transfer Pricing Tips for taxpayers approaching Cloud computing in their transfer pricing documentation When many people have difficulty even defining what Cloud computing is, for a taxpayer in a multinational company, being able to account for the business’s use of Cloud computing for tax purposes can be a nightmare, p... By Sophie Ashley January 30 2014
This content is from: United Kingdom UK thin capitalisation: An overview of the theory and practice Liz Hughes and Oriana Panidha of Grant Thornton discuss thin capitalisation in the context of HMRC’s increasing scrutiny of the arm's-length nature of interest applied to the lending and borrowing amongst related part... By ITR Correspondent January 30 2014
This content is from: European Union Why Germany prevented EU JTPF from providing workable solution to compensating adjustments The EU’s Joint Transfer Pricing Forum (JTPF) has published a report on compensating adjustments, designed to bring more guidance for taxpayers, particularly those operating in European member states. But members of th... By Sophie Ashley January 28 2014
This content is from: Switzerland Stephen Alleway joins new transfer pricing advisory firm Questro January 24 2014
This content is from: Canada McKesson Canada: CRA wins in Tax Court but taxpayer files with Court of Appeal The Canada Revenue Agency (CRA) saw pharmaceutical company McKesson’s arguments dismissed by the Tax Court in December 2013 but the company has now filed its arguments with the Federal Court of Appeal. By Sophie Ashley January 24 2014
This content is from: Transfer Pricing How to organise your TP department to avoid dispute Governments' hard-line approaches to companies' transfer pricing arrangements has resulted in a rise in transfer pricing cases being resolved in court, explains Fabrizio Lolliri, European director of transfer pricing ... January 21 2014
This content is from: Transfer Pricing The new cost of global compliance: Private company data for local comparables All of us in the tax world know that transfer pricing has been a hot topic this year. Around the globe, tax authorities have become more aggressive, primarily to reduce government fiscal deficits. January 20 2014
This content is from: Italy Why the OECD may look at capital receipts but India is unlikely to get its income tax w... India wants the OECD and the UN to consider the issue of capital receipts. The Ministry of Finance would like to see a more international acceptance of the recharacterisation of capital transactions as loans where int... By Sophie Ashley January 17 2014
This content is from: United States The implications of oligopoly markets in transfer pricing International tax attorney and transfer pricing economist John Drewno of Caterpillar discusses the comparable company data issues that multinational corporations (MNCs) face when operating in an oligopoly market struc... January 17 2014
This content is from: Italy Update on Italian regional tax on productive activities brings clarity Before 2014, IRAP (the Italian regional tax on productive activities) regulations gave rise to some interpretative difficulties when transfer pricing issues were involved, especially during tax audits and assessments. By ITR Correspondent January 14 2014
This content is from: European Union Why a broad brush approach to transfer pricing will not satisfy taxpayers It is increasingly difficult for transfer pricing to be applied generally to industry. Different trades require different approaches and practices from their transfer pricing operations and advisers and governments ne... By Sophie Ashley January 14 2014
This content is from: Italy Italian Supreme Court reinforces arm's-length principle Piergiorgio Valente, managing partner of Valente Associati GEB Partners, discusses a Supreme Court ruling (17955/2013) and its impact on the arm’s-length principle. January 09 2014
This content is from: United Kingdom Tate & Lyle on how to review and set new transfer pricing policies in a rapidly changin... Fabrizio Lolliri, European director of transfer pricing at Hogan Lovells, and Catherine Clare, international tax manager at Tate & Lyle, a UK-based multinational agribusiness, explain how to make the most of your rela... January 08 2014
This content is from: Poland Transfer pricing developments in Poland The amended Decree from the Ministry of Finance on the methods and procedures of determining taxable income, by estimating prices and the methods and procedures of eliminating double taxation in the case of a transfe... By ITR Correspondent January 08 2014
This content is from: India Ajit Tolani leaves ELP to set up own practice By ITR Correspondent January 07 2014
This content is from: United States Miller & Chevalier takes Linda Carlisle from White & Case By ITR Correspondent January 06 2014
This content is from: Direct Tax Vote now for the top tax transactional and tax planning firms Two forthcoming issues of International Tax Review will include surveys of the leading tax transactional (March) and tax planning firms (May) around the world. The firms will be ranked after polls of corporate taxpaye... By Matthew Gilleard January 02 2014
