Transfer Pricing

Archive: Transfer Pricing

This content is from: India

Indian government decides not to appeal Bombay High Court ruling in Vodafone case

The Indian government will not appeal the Bombay High Court (HC) ruling which concluded Vodafone was not accountable for a 3,200 crore ($525 million) tax demand.
By Sophie Harding

& Joseph Stanley-Smith
January 28 2015
This content is from: Sponsored

German tax planning: Anti-hybrid financing measures

Germany has acted before the OECD’s final recommendations on hybrid mismatches by including anti-hybrid financing measures in the 2013 Annual Tax Act. Oliver Wehnert and David Martiny of EY explore whether the German ...
January 28 2015
This content is from: United States

MAP and bilateral APA agreements with US signal breakthrough for India

Mutual agreement procedures (MAPs) and advance pricing agreements (APA) between India and the US hint at closer ties between the two nations and reinforce India’s desire to be seen as an investor friendly country.
By Sophie Harding
January 28 2015
This content is from: India

Indian Government will not appeal Vodafone decision

The Indian Government has decided not to appeal the Bombay High Court (HC) ruling which stated Vodafone was not liable to pay a 3,200 crore ($525 million) tax demand.
By Sophie Harding - ITR

& Joe Stanley-Smith
January 28 2015
This content is from: Sponsored

New era for dependent agent PEs in Germany?

Susann van der Ham and Guido Schepers of PwC discuss the recently approved ordinance on the application of the arm’s-length principle to permanent establishments (PEs), addressing the impact of the introduced section ...
January 28 2015
This content is from: Canada

U-turn in CBSA’s stance on TP adjustments for customs purposes is welcome news for impo...

The Canada Border Services Agency (CBSA) recently changed its policy on transfer pricing adjustments for customs purposes. The new policy allows eligible importers to seek refunds of custom duties where transfer price...
By Sophie Harding
January 27 2015
This content is from: Sponsored

BEPS – Preventing treaty abuse: A practical perspective

Keith Brockman, global tax director at Mars and author of the International Tax Best Practices blog, analyses BEPS Action 6 on preventing treaty abuse, calling for more balance in seeking to avoid double taxation and ...
January 27 2015
This content is from: Brazil

Analysing the Brazilian tax authorities’ approach to royalty payments

A series of articles which will address the issues taxpayers face with the Brazilian tax authorities when dealing with royalty payments.
By ITR Correspondent
January 27 2015
This content is from: Global

Moving goalposts mean taxpayers must stay on toes

Joe Stanley-Smith analyses how new attitudes and initiatives from tax authorities in key jurisdictions will influence the national and international tax dispute landscape in 2015.
January 27 2015
This content is from: Transfer Pricing

BEPS Action 10 feedback shows cost pool remains a contentious issue

Public comments on BEPS Action 10 welcome the OECD’s simplified approach to dealing with low value-adding intra-group services and generally support the proposed profit mark-up range. However, feedback has stressed th...
By Sophie Harding
January 26 2015
This content is from: Canada

Taxpayers on whether TP service providers are meeting industry needs

As transfer pricing (TP) becomes more demanding for multinational companies their need for TP service providers with industry experience increases.
By Sophie Ashley
January 26 2015
This content is from: Transfer Pricing

Business speaks out on preventing treaty abuse

Businesses have made their feelings clear about the OECD’s work on preventing treaty abuse, which is a sub-section of the organisation’s work on base erosion and profit shifting (BEPS).
By Sophie Ashley
January 26 2015
This content is from: Transfer Pricing

Why it is crucial the OECD’s work on dispute resolution succeeds in the eyes of business

The chairman of BIAC’s tax committee, Will Morris, made an address to the OECD’s consultation on dispute resolution last week and said success on the dispute resolution action item is crucial to the overall success of...
January 26 2015
This content is from: Transfer Pricing

BIAC's opening remarks at OECD's consultation on preventing artificial avoidance of PE

Will Morris, the chairman of the BIAC Tax Committee delivered his opening remarks to the OECD at the consultation on preventing the artificial avoidance of PE status this week.
January 23 2015
This content is from: India

Mumbai ITAT sides with OECD on location savings in Watson Pharma case

The Income-Tax Appellate Tribunal (ITAT) in Mumbai has ruled in favour of Watson Pharma Private, rejecting India’s views on location savings advantages in favour of the OECD perspective.
By Sophie Harding
January 22 2015
This content is from: Transfer Pricing

Action 7 feedback downplays OECD’s progress and hints at unravelling of universal approach

Comments on Action 7 of the OECD’s base erosion and profit shifting (BEPS) project show the draft has done little to clarify permanent establishment (PE) issues with many countries considering national measures to tac...
By Sophie Harding
January 21 2015
This content is from: United Kingdom

Taxpayers worried about UK’s DPT implementation and timeline

Following the UK’s announcement of the proposed Diverted Profits Tax (DPT) in December, there have been numerous doubts voiced regarding the policy drivers, mechanics and timing of the proposals.
By ITR Correspondent
January 21 2015
This content is from: European Union

Growing fear over wider implications of EC investigations after Amazon Luxembourg deal ...

In a preliminary ruling, the European Commission (EC) has deemed tax deals between Luxembourg and Amazon as state aid.
By Sophie Harding
January 20 2015
This content is from: South Africa

Drastic changes to South African TP regime needed to align country with OECD BEPS work

The Davis Tax Committee recently published recommendations for the OECD and the South African Revenue Service (SARS) regarding base erosion and profit shifting (BEPS). The committee’s comments highlight the lack of co...
By Sophie Harding
January 19 2015
This content is from: Singapore

Singapore updates its transfer pricing guidelines

The Singapore revised transfer pricing (TP) guidelines, published January 6 2015, require taxpayers to prepare and maintain contemporaneous TP documentation to support TP positions and have this in place by the time t...
January 19 2015
This content is from: Colombia

Takeda Pharmaceuticals hires Francisco Zamora to lead its LatAm tax team

Takeda Pharmaceuticals has recruited Francisco Jose Zamora Valencia to the role of regional tax manager for the Latin America region excluding Brazil.
January 19 2015
This content is from: India

India signs first ever bi-lateral APA with Japanese company

In December, India’s Central Board of Direct Taxes (CBDT) signed the first bi-lateral advance pricing agreement (APA) with a Japanese company.
By Meredith McBride
January 16 2015
This content is from: Canada

McKesson saga continues with new filing by taxpayer

McKesson has filed a supplementary memorandum of fact and law after the Court of Appeal deemed its initial memorandum too lengthy. The controversial transfer pricing case, involving a trial judge’s recusal, appears un...
By Sophie Harding - ITR
January 14 2015
This content is from: Ukraine

New TP reforms in Ukraine likely to ramp up disputes and prolong audits

The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pric...
By Sophie Harding
January 14 2015
This content is from: United Kingdom

UK takes profit shifting into its own hands with DPT proposal

The UK government’s plans to introduce a Diverted Profits Tax (DPT), before the completion of the OECD’s work on base erosion and profit shifting (BEPS), could create uncertainty within the UK’s tax system despite bei...
By Sophie Harding
January 14 2015
This content is from: China

China’s APA stats show acceptance of different TP methods

China’s State Administration for Taxation (SAT) released its advance pricing agreement (APA) statistics for 2013 on December 5 2014.
By Sophie Ashley
January 12 2015
This content is from: China

China focuses on cross-border transactions in war on tax evasion

The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. The move signals a crackdown on profit shifting, which could see...
By Sophie Harding
January 12 2015
This content is from: Canada

McKesson saga continues with new filing by taxpayer

McKesson has filed a supplementary memorandum of fact and law after the Court of Appeal deemed its initial memorandum too lengthy. The controversial transfer pricing case, involving a trial judge’s recusal, appears un...
By Sophie Harding
January 08 2015
This content is from: Hong Kong SAR

Lack of transfer pricing rules leads to questionable audits in Hong Kong

Despite a self-touted reputation as a leading global financial centre, Hong Kong’s Inland Revenue Department (IRD) has been criticised by tax practitioners for overly aggressive audits on asset managers. Hong Kong has...
By Meredith McBride
January 08 2015
This content is from: India

Indian CBDT launches new dispute resolution framework to silence critics

The Central Board of Direct Taxes (CBDT) in India has introduced a new dispute resolution framework in an attempt to bring greater neutrality to tax dispute resolution and encourage multinationals to do more business ...
By Sophie Harding
January 07 2015
This content is from: Italy

The transfer pricing implications of the Italian regional tax on productive activities

The provincial tax court of Reggio Emilia has issued ruling No 510/03/14 relating to the Italian regional tax on productive activities (IRAP).
By ITR Correspondent
January 06 2015
This content is from: Direct Tax

Vote now for the past year's top tax transactional and tax planning firms
By Matthew Gilleard
January 02 2015

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