China’s transfer pricing regulations, which were published on January 9, will affect how companies manage their tax affairs and add to their compliance costs, say tax directors
February 11, 2020
The OECD has released mutual agreement programme (MAP) statistics for 2010. Canada, Germany and Poland tell TPWeek what these stats mean for them.
December 14, 2011
While all taxpayers deal with intellectual property (IP), and the evaluation issues surrounding it for taxation purposes, some taxpayers place more value on it than others. Paul Morton, the head of tax for publishing house, Reed Elsevier, explains the practical day-to-day problems surrounding IP, when operating on a global scale.
December 08, 2011
In transfer pricing, the main problem for practitioners is to choose which method they will use to calculate an arm’s-length price. They must also decide which profit level indicator (PLI) they will select to support their argument.
November 23, 2011
The UK team has also undergone a number of internal changes.
January 24, 2012
The new head of the OECD's tax treaty, transfer pricing and financial transactions division has been named.
January 11, 2012
December 21, 2011
December 15, 2011
December 15, 2011
The Netherlands has introduced a deduction for capital expenditure associated with R&D, effective January 1 2012, which has implications for transfer pricing.
January 10, 2012
The Hong Kong Inland Revenue Department (IRD) will launch an advance pricing agreement (APA) programme in April.
January 09, 2012
The outline for Japanese tax reform proposals was released on December 26 2011 with changes to intercompany loan regulations.
January 06, 2012
China has underlined its determination to strengthen its anti-avoidance rules by concluding the country’s first thin capitalisation audit.
January 03, 2012
The Indonesian government has introduced a number of changes to its transfer pricing regime that will affect the way taxpayers apply the arm’s-length principle on related party transactions.
December 13, 2011
A recent ruling by the Tax Tribunal of Korea said companies that make transfer pricing adjustments after reporting importation to customs will not be refunded.
January 05, 2012
The OECD is considering the Canadian Alberta Printed Circuits transfer pricing dispute as a case study in its intangibles project, according to the company’s expert witness.
December 13, 2011
While all taxpayers deal with intellectual property (IP), and the evaluation issues surrounding it for taxation purposes, some taxpayers place more value on it than others. Paul Morton, the head of tax for publishing house, Reed Elsevier, explains the practical day-to-day problems surrounding IP, when operating on a global scale.
December 08, 2011
The District Court of the Hague has ruled, in a transfer pricing dispute, that the profits of an Irish reinsurance company are considered taxable income for its Dutch shareholder. Eduard Sporken and Dirk Brouwers of KPMG Meijburg & Co discuss the case and its implications.
September 12, 2011
By Barbara Dooley and Gavan Ryle of PwC, Dublin.
June 23, 2011
Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador
March 23, 2011
Todd Miller and Michael Friedman of McMillan in Toronto, Canada explain the documentation rules in Canada and how recent treaty developments and court decision will affect taxpayers.
April 20, 2010
Steven Tseng, Chi Cheng, Kari Pahlman and Nathan Richards of KPMG China outline the transfer pricing documentation guidelines in Hong Kong and China.
March 29, 2010
Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime.
March 08, 2010
Ken Okawara, Yukiko Komori, Satoko Kawamura, and Koji Oshima of Baker & McKenzie GJBJ Tokyo Aoyama Aoki Koma Law Office (Gaikokuho Joint Enterprise) review the Japanese documentation situation.
March 01, 2010
Anthony Mahon and Andy El Zayaty of Deloitte provide a guide to the transfer pricing requirements in Egypt.
December 15, 2010
Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore.
February 22, 2010
Tae-Yeon Nam, Dong-Jun Yeo and Stefan Moller, Kim and Chang, Seoul
July 14, 2009
Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers
February 11, 2009
Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing
June 03, 2008
Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping
June 05, 2008
Cristiane Magalhães and Fabíola Costa Girão, of TP Week correspondent Machado Associados, analyse the impact of double tax treaties on transfer pricing policy in Brazil
June 04, 2008
In the second in our series on double tax treaties, Gustavo López-Ameri of Deloitte & Touche in Lima reports on Peru's transfer pricing policy
May 30, 2008
KR Girish and Rohit Jain, of TP Week correspondent KPMG in India look at the impact of double tax treaties and transfer pricing
May 28, 2008
Hardev Singh and Saurabh Dhanuka, of KPMG, TP Week’s correspondent in India, give practical advice on dealing with India’s revenue authorities
May 22, 2008
Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta
April 15, 2008
Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process
April 07, 2008
Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit
April 06, 2008
Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland
March 14, 2008