This content is from: Brazil Why Brazilian companies may qualify for reimbursement for shared expenses The Brazilian tax authority has released an opinion which states that expenses, relating to shared services between related entities, may be considered tax deductable for the Brazilian company benefitting from the ser... By Sophie Ashley February 27 2014
This content is from: United States Special features - March 2014 Read this month's special feature on tax audits. February 26 2014
This content is from: Greece Guide to negotiating APAs in Greece The Greek Ministry of Finance has issued a ministerial decision regulating the procedure to be followed for the negotiation of advance pricing agreements (APA), applicable from January 1 2014. February 26 2014
This content is from: China The economics of location specific advantages Multinational corporations (MNCs) have been relocating portions of their global supply chain to developing countries, including India and China, to generate efficiencies and remain competitive in the marketplace. February 25 2014
This content is from: France French tax authority merges APA and MAP programmes The French tax authorities have officially announced the creation of a new group to deal with its advance pricing agreements (APA) and mutual agreement procedures (MAP). By Sophie Ashley February 24 2014
This content is from: United States Negotiating the venture valuation model and cost sharing rules Cost sharing agreements can present certain difficulties for taxpayers. The IRS regulations published in 2011 included commensurate with income (CWI) rules, which are affected by different valuation methods. The ventu... February 20 2014
This content is from: United States Intangible assets in the media and entertainment industries: In depth analysis The US television production industry reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look... February 18 2014
This content is from: United States IRS releases transfer pricing audit roadmap The Internal Revenue Service (IRS) has released a roadmap for transfer pricing audit designed as a reference tool for taxpayers involved in typical 24-month audits. By Sophie Ashley February 17 2014
This content is from: Ecuador The Altus Alliance expands its network in Spain and Ecuador February 12 2014
This content is from: Transfer Pricing TP regulation round-up: Iceland and Guatemala Iceland has recently enacted transfer pricing legislation but Guatemala has announced its laws will be delayed until 2015. By Sophie Ashley February 11 2014
This content is from: United Kingdom SMEs are not keeping pace with HMRC’s transfer pricing approach HM Revenue & Customs (HMRC) has been targeting mid-sized companies’ transfer pricing arrangements and has increased its yield over the 2012 to 2013 accounting period by more than £100 million ($164 million) on the pre... By Sophie Ashley February 11 2014
This content is from: United States OECD seeks increased tax transparency from multinationals The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations. By ITR Correspondent February 06 2014
This content is from: India The transfer pricing considerations of Suzuki’s 100% subsidiary in India Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implicati... By Sophie Ashley February 04 2014
This content is from: Transfer Pricing Country by country reporting and the changing landscape The OECD issued a draft revised chapter V of the OECD guidelines on documentation on January 30 2014. The emphasis is now on both transfer pricing enquiry and on risk assessment. One of the key changes to help tax au... By ITR Correspondent February 03 2014
This content is from: Transfer Pricing Permanent establishment special focus Permanent establishment (PE) is becoming more complicated as regulators find it hard to keep pace with a rapidly developing digital economy. Taxpayers regularly find themselves in difficulty trying to decide whether c... February 03 2014
