Transfer Pricing

Archive: Transfer Pricing

This content is from: Sponsored

International updates - May 2014

The latest international updates from our correspondents around the world.
April 30 2014
This content is from: Australia

Australia and Canada worlds apart on country-by-country reporting

Countries with their own transfer pricing reporting forms, such as Canada and Australia, have a strong case to stick to their own standards rather than adopt the OECD’s universal approach because of their greater rele...
By Sophie Harding
April 30 2014
This content is from: Turkey

Recharacterisation of professional service income

Güler Hülya Yilmaz and Lerzan Nalbantoglu of Deloitte look at a case leading to mutual agreement process.
April 30 2014
This content is from: Turkey

Taxation of foreign funds

Firat Yalçin of Pekin & Pekin looks at the taxation of foreign funds in Turkey.
April 30 2014
This content is from: Canada

Cameco looks ahead to its 2015 Canada Tax Court trial

Canadian uranium mining company, Cameco, has discussed its transfer pricing assessments with the Canada Revenue Agency (CRA) and has made assumptions about its upcoming trial in the Tax Court.
By Sophie Ashley
April 30 2014
This content is from: Turkey

Loss compensation fund contributions

Güler Hülya Yilmaz of Deloitte asks: Can a loss compensation fund be treated as a consideration in return for a transaction between related parties?
April 30 2014
This content is from: Turkey

Attribution of income to PEs in EPC contracts

Güler Hülya Yilmaz of Deloitte reports on why the attribution of income to permanent establishments (PEs) in the case of EPC contracts is an important taxation issue for contractors in the energy industry.
April 30 2014
This content is from: Canada

Managing TP risks in Nigeria: The importance of proactivity

Nigerian transfer pricing rules are still in their relative infancy, but taxpayers must take adequate steps to prepare now if they are to effectively identify risk areas and plan with both the company policy and the p...
April 29 2014
This content is from: Turkey

Special features - May 2014

Read this month's special features on Turkey and tax technology.
April 29 2014
This content is from: Ireland

The journey into the future for Swiss principal companies?

Urs Landolf, Martina Walt and Christoph Pauli of PwC explain the impact new interpretations of principal company taxation by the Swiss federal tax authorities will have on all existing companies benefiting from circul...
April 29 2014
This content is from: Global

According to plan? The world of tax planning is changing, but not as fast as everyone w...

The world of tax planning is like one big global tug o’ war being played between multinational companies and their advisers, tax authorities, supranational bodies and non-governmental organisations. Everyone has an in...
April 29 2014
This content is from: Greece

New Greek transfer pricing guidance provides clarity

Greece’s Finance Minister has issued a ministerial decision that provides guidance on the contents of the transfer pricing documentation file, the parties subject to the transfer pricing rules and exemptions , languag...
By ITR Correspondent
April 27 2014
This content is from: Direct Tax

Caterpillar: A BEPS case study

At the end of March, multinational manufacturer of construction and mining equipment, Caterpillar, was brought before the US Senate to explain its tax affairs, accused of profit shifting and aggressive tax planning. M...
April 23 2014
This content is from: Australia

Taxpayers fearful of Australia’s tightening grip on TP legislation

The release of draft taxation rulings by the Australian Tax Office (ATO) this month has left many tax professionals fearful of its extensive power and ever growing control over transfer pricing issues.
By Sophie Harding
April 23 2014
This content is from: Russia

Russian TP legislation still not hitting the mark

A number of key changes have been made to the Russian Tax Code, affecting transfer pricing (TP) documentation requirements as of 2014 onwards. While the extension of the scope and application of the legislation is pos...
By Sophie Harding
April 22 2014
This content is from: Indonesia

Why TP litigation is still a struggle in Indonesia

Despite some positive developments in the transfer pricing dispute resolution scene in Indonesia, taxpayers are still struggling with litigation and looking for alternatives.
By Sophie Ashley
April 22 2014
This content is from: European Union

UK Treasury defends Patent Box against EC threat

The UK’s Patent Box could face amendments depending on the outcome of an EC investigation into whether it constitutes harmful tax competition that disadvantages other European member states.
By Sophie Ashley
April 16 2014
This content is from: European Union

UK Treasury defends Patent Box against EC threat

The UK’s Patent Box could face amendments because the EC is investigating whether it constitutes harmful tax competition with other European member states.
By Sophie Ashley
April 16 2014
This content is from: India

New partner at BMR & Associates
April 16 2014
This content is from: Brazil

Why Brazilian authorities are treating BEPS as a case study

As a non-OECD country, Brazil will not be overtly affected by the outcome of the Base Erosion and Profit Shifting (BEPS) project. However, recent discussions suggest that interest is increasing and support for the OEC...
By Sophie Harding
April 16 2014
This content is from: Netherlands

Starbucks moving European HQ to London

Starbucks is set to pay more tax in the UK after today announcing it will move its European headquarters from the Netherlands to London. It has also pledged to create 1,000 new jobs in the country.
By Matthew Gilleard
April 15 2014
This content is from: Serbia

Amendments to TP rules in Serbia

In January 2014 the Ministry of Finance adopted amendments to the Serbian transfer pricing (TP) rulebook to ease certain TP requirements and resolve ambiguities and technical errors.
April 13 2014
This content is from: Netherlands

Netherlands intangibles guide

By Peter Flipsen and Anouc van den Berg, of Simmons & Simmons Amsterdam.
April 12 2014
This content is from: United States

DLA Piper hires ex-Barclays TP economist
April 10 2014
This content is from: European Union

Defeat for UK government as European Court of Justice rules in favour of Hutchison Whampoa

Hutchison Whampoa recently won a bid for tax relief on losses by its UK mobile phone unit, Three, after the European Court of Justice (ECJ) found that Britain had violated EU anti-discrimination rules by blocking the ...
April 10 2014
This content is from: United States

US Multistate Tax Commission discusses launch of interstate TP audit programme

The US Multistate Tax Commission (MTC) has announced it aims to launch an interstate transfer pricing (TP) audit programme in July 2015. The move was brought on by Michael Bryan, director of the New Jersey Division of...
By Sophie Harding
April 10 2014
This content is from: Transfer Pricing

Research process has started for World Transfer Pricing directory 2015

The research has started for World Transfer Pricing 2015 and World Tax 2015, International Tax Review's directories of the leading tax and transfer pricing firms around the world.
By Sophie Ashley
April 09 2014
This content is from: United States

What the new IRS transfer pricing audit roadmap means for multinationals

The Internal Revenue Service (IRS) released its Transfer Pricing Audit Roadmap, in February, which is a 26 page document advertised as a “practical, user-friendly toolkit” for IRS transfer pricing specialists as well ...
By ITR Correspondent
April 08 2014
This content is from: Brazil

Brazilian authorities change stance on withholding tax

The Brazilian tax authorities have adapted their stance on withholding tax (WHT) for technical services (without transfer of technology) for beneficiaries domiciled in countries that have a double tax agreement with B...
April 07 2014
This content is from: India

How OECD’s country-by-country proposals will impact India

The OECD’s country-by-country reporting (CBCR) discussion draft elaborates on its White Paper on Transfer Pricing Documentation, which was released on July 30 2013.
By ITR Correspondent
April 06 2014
This content is from: United Kingdom

UK backing of OECD’s BEPS project hints at weakening stance on interest deductions

The Treasury recently announced its support for a planned revamp of global tax rules which it warned would not always result in increased UK revenues or taxing rights. This has led many in the tax industry to worry ab...
By Sophie Harding
April 03 2014
This content is from: United States

US APMA stats for 2013 show promise but proposals have negative undertones

New proposals for APA and MAP applications, released during the last quarter of 2013, reflect changes in the advance pricing and mutual agreement programme’s (APMA) structure. The proposals emphasise a desire to resol...
By Sophie Harding
April 02 2014
This content is from: United States

New TP director at WTP Advisors
April 02 2014
This content is from: India

Sid Paruthi joins Apple from EY as head of TP
April 02 2014
This content is from: Transfer Pricing

BEPS and its interraction between TP and indirect tax

The potential impact of the OECD’s BEPS project on indirect tax is a topic that has been overshadowed, with discussions focusing on intangibles and country-by-country Reporting (CBCR); however, it remains an important...
By Sophie Harding
April 01 2014

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