This content is from: Australia Determining the transfer pricing policy for liquefied natural gas Tamir Druz, a director at Capra Energy Group, discusses the best methods for determining an optimal transfer pricing policy for liquefied natural gas (LNG). August 31 2014
This content is from: Global World Tax Authority: Taking harmonisation to the next level Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Aut... August 28 2014
This content is from: Global The IMF and international tax David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation. August 28 2014
This content is from: United States Going the extra mile - when finance and IT suddenly awoke In the July/August issue, Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group, took a retrapolative look at the country-by-country reporting standard fiv... August 28 2014
This content is from: Brazil Alternative dispute resolution: Alleviating burdens all round The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well esta... August 28 2014
This content is from: United Kingdom New UK measures to counter avoidance schemes in line with OECD’s BEPS initiative HM Revenue & Customs (HMRC) has announced new measures to dissuade taxpayers from using avoidance schemes which involve the transfer of corporate profits. Taxpayers will need to familiarise themselves with the new mea... By Sophie Harding August 27 2014
This content is from: India Motorola shows a way forward in capital asset pricing model A recent case involving Motorola Solutions India has shown taxpayers a way forward in the use of the capital asset risk pricing model for carrying out risk adjustment. By ITR Correspondent August 27 2014
This content is from: Russia Why Russia’s stance on TP guidelines could result in double taxation In a recent conference, acting head of transfer pricing for the Russian Federal Tax Service, Vladimir Golishevsky, discussed when it is suitable for taxpayers to rely on OECD guidelines. Golishevsky’s statement demo... By Sophie Harding August 25 2014
This content is from: Canada Leading Canadian transfer pricing cases favour domestic rules over OECD guidelines Until the decision in the GlaxoSmithKline (Glaxo) case, all previous Canadian court decisions had slavishly applied the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. How do ... August 20 2014
This content is from: Transfer Pricing Profit splits and value chain analysis key to addressing transfer pricing issues in the... Paul Morton, head of group tax for Reed Elsevier, writes about the transfer pricing methodologies required for a rapidly developing digital economy. August 17 2014
This content is from: United States IRS roadmap makes way for flexibility in TP audit process The IRS transfer pricing audit roadmap was created to improve the efficiency and consistency of transfer pricing audits, placing greater emphasis on the process of individual cases. By Sophie Harding August 13 2014
This content is from: Singapore Singapore: Transfer pricing aspects of restructuring By Luis Coronado and Stephen Lam, Ernst & Young Singapore August 13 2014
This content is from: United States Inversions - special focus Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide sys... By Matthew Gilleard August 09 2014
This content is from: China China intangibles guide By Qisheng Yu, Amy Cai and Wing Siu, PwC China August 09 2014
This content is from: Brazil New CFC rules exclude transfer pricing adjustments from profits generated abroad Alterations made to controlled foreign corporation (CFC) legislation in Brazil will have a significant impact on the way taxpayers look at foreign profits. By ITR Correspondent August 07 2014
This content is from: Russia Russia: Transfer pricing aspects of restructuring By Evgenia Veter, Steve Cawdron and Anuar Mukanov of EY Russia August 07 2014
This content is from: China China shows signs of OECD guideline acceptance China has demonstrated a certain degree of resistance towards the OECD guidelines and adopting international policies but it is beginning to show signs of acceptance. By Sophie Harding August 06 2014
This content is from: United States Americas Awards 2014 nominations released The nominations for the Americas Tax Awards, which take place in New York on September 18, have been announced. August 06 2014
This content is from: United States Amazon struggles to resolve $1.5 billion dispute with IRS The international e-commerce company, Amazon, has failed to resolve elements of its transfer pricing dispute with the Internal Revenue Service (IRS). The case revolves around the retailer’s use of a European subsidiar... By Aaran Fronda August 05 2014
This content is from: United States Incomplete intangibles guide suggests OECD’s September deadline was overly ambitious On July 23, Michelle Levac, chair of Working Party No 6, announced that the revised chapter on intangibles, to be released in September, will not be final guidance. By Sophie Harding August 04 2014
