This content is from: Direct Tax ITR launches app! The International Tax Review app is now available! International Tax Review subscribers can now download the ITR app, giving them full access to the latest ITR articles while they are on the go. May 31 2015
This content is from: India India and Japan work on mutual agreement but ignore crux of issue India and Japan are working to resolve a number of disputes through the mutual agreement programme (MAP) showing a resolution to improve the dispute atmosphere in India. By Sophie Ashley May 28 2015
This content is from: Transfer Pricing How to use technology to gain control of your TP operations at a global level The list of up and coming international tax regulations might look like a plate of alphabetti spaghetti but, whether talking about base erosion profiting shifting (BEPS), country-by-country reporting (CbCR), operation... May 27 2015
This content is from: United States Businesses report difficulties in obtaining APAs with China Though China has had an advance pricing agreement (APA) programme for nearly a decade, some businesses report that obtaining APAs in China is challenging due to a lack of manpower at the State Administration of Taxati... By Meredith McBride & Joe Stanley-Smith May 27 2015
This content is from: Mexico Implementing the BEPS Action Plan in Mexican domestic law One of the concerns that has arisen for governments around the world is the erosion of the national tax base caused by a globalised economy, the progress of technology and the development of telecommunications. Ricard... May 26 2015
This content is from: Sweden The Swedish Tax Agency’s difficulty in meeting its burden of proof The Swedish Tax Agency (STA) bears the burden of proof that pricing between associated companies differs from what would have been agreed between independent companies but this burden has proved difficult for it to meet. By ITR Correspondent May 26 2015
This content is from: Global BEPS: Improving data, economic analysis and measurement It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together... May 26 2015
This content is from: Global The Brockman brief: UK diverted profits tax: The extrapolation effect The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance an... May 26 2015
This content is from: India Indian government seeks comments on range concept and multiple year data by end of the ... On May 21, the Central Government issued a draft scheme on range concept and use of multiple year data and invited comments and suggestions from stake holders and general public by 31 May 2015. By ITR Correspondent May 26 2015
This content is from: Italy Why CUP is the preferred method in Italy A recent Italian court ruling has emphasised that comparable uncontrolled price (CUP) is the most suitable approach to quantifying an arm’s-length value. By ITR Correspondent May 20 2015
This content is from: Brazil How non-OECD members differ in asset management transfer pricing Marcelo Vicentini of Standard Chartered in Brazil discusses the differences between OECD member countries and non-members when it comes to asset management transfer pricing. May 17 2015
This content is from: United States How China’s tax and TP amendments will affect your business model This year is shaping up as an extraordinary and somewhat disturbing year in China when it comes to tax and transfer pricing. New rules are being released that will change the tax calculus and risk curve for multinatio... May 17 2015
This content is from: Germany Why dispute resolution between Germany and India is a lost cause The worldwide transfer pricing landscape is in a state of flux and the need for sound and reliable dispute resolution mechanisms has never been more important for multinational enterprises. By ITR Correspondent May 13 2015
This content is from: Indonesia How Indonesia plans to curb transfer pricing abuse through Singapore Indonesia is planning to cut its corporate tax rate to compete with Singapore and curb the amount of taxable profit leaving the country. By Sophie Ashley May 13 2015
This content is from: South Africa SARS criticised by judge for failing to curb TP abuse The South African Revenue Service (SARS) has been criticised for its failure to curb transfer pricing abuse by a judge in charge of Parliament’s tax review committee. By Sophie Ashley May 11 2015
This content is from: United Kingdom BEPS and what it means to the UK investment management industry The UK investment management industry is an important part of the UK financial services sector and whilst the Conservative-Liberal Democrat coalition’s stated aim is "to create the most competitive tax system in the G... By ITR Correspondent May 06 2015
This content is from: India Why foreign institutional investors should not be put under minimum alternate tax Foreign institutional investors (FII) risk being subject to a minimum alternate tax (MAT) on gains made on the purchase and sale of shares on the Indian stock market. May 05 2015
This content is from: Australia BHP Billiton faces $432 million tax bill in Australia The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a ... By Meredith McBride in Hong Kong May 05 2015
