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Previously, TPWeek reported on multinationals’ decrease in demand for outsourced transfer pricing advice. Advisers explain how they are keeping up with market trends and how the approach of accountants and lawyers varies. February 07, 2012
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Experts are applying a new technique to avoid the application of the Brazilian resale price minus method. February 01, 2012
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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
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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
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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
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A New Zealand court case involving debt finance is creating waves because it seems the Inland Revenue Department (IRD) is contradicting its own guidelines. September 16, 2011
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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
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The case of Symantec Software Solutions Pvt Ltd, heard before the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), has implications for the application of transfer pricing provisions, which continue to differ from global best practice.
August 17, 2011
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The Delhi Tribunal, in the case of CRM Services, a call centre provider, has passed a relevant ruling for captive IT enabled or business process outsourcing (BPO) service providers. July 27, 2011
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A Czech Supreme Administrative Court ruling has set groundbreaking rules for the burden of proof in transfer pricing cases. Libor Frýzek and René Kulínský, of Ernst & Young, discuss. June 10, 2011
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The Australian Tax Office (ATO) has lost its appeal against the taxpayer, SNF, at the Full Federal Court in a transfer pricing case concerning comparables and method application. June 08, 2011
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A French company has lost its appeal at the Nantes Administrative Court over the burden of proof and the assignment of affiliated company liabilities in transfer pricing. June 08, 2011
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Two recent cases in the US, Medtronic and Guidant, highlight the Obama administration’s budget proposals to clarify the law regarding foreign intangible assets. June 01, 2011
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In the latest transfer pricing case to emerge in Canada, the taxpayer has won a judgment from the Tax Court over reassessments made by the Canada Revenue Agency (CRA) worth about C$2.7 million ($2.7 million) even though the taxpayers’ transactions were found to contravene the arm’s-length principle. May 25, 2011
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In the Canadian Alberta Printed Circuits (APC) transfer pricing case, the decision relied extensively on the evidence given by expert witnesses on behalf of the taxpayer and the Canadian Revenue Agency (CRA). May 25, 2011
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Taxpayers can no longer use companies with segmental results, or those with a comparatively low turnover, as a comparable for benchmarking purposes under transfer pricing provisions in India. May 04, 2011
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Computer company IBM has lost a two-year dispute with the Australian Tax Office (ATO) over royalties paid to its American parent. April 20, 2011
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Media company, Bloomberg, will not appeal a Russian court decision that said its Russian operations constituted a permanent establishment (PE). April 13, 2011
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A Norwegian Court of Appeal ruled on March 2 that Dell AS, a Norwegian commissionaire company, constituted a sales agency permanent establishment (PE) in Norway because of its undisclosed Irish principal. April 11, 2011
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Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC). April 06, 2011
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The Canada Revenue Agency has been given leave to appeal the GlaxoSmithKline case to the Supreme Court. A cross-appeal from the taxpayer was also accepted. March 25, 2011
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The Mumbai Income Tax Tribunal (ITAT) has sent back the file of Teva India, dealing with pharmaceuticals, to the transfer pricing officer (TPO) to reassess whether Vimta Labs, a contract research and testing organisation with abnormally high profit, is comparable to a contract R&D provider. March 22, 2011
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A Johannesburg Tax Court decision suggests taxpayers should be able to prove the arm’s length nature of domestic, as well as cross-border, intra-group transactions. March 16, 2011
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A legal battle between Exportadora Bananera Noboa (EBN), Ecuador’s largest corporate conglomerate, and the Tax Administration (SRI) is coming to an end in Ecuador, setting important precedents for the transfer pricing of commodities. Alexis Carrera, of Ernst & Young in Quito, analyses the case. March 15, 2011
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The Brazilian Taxpayer’s Council, responsible for analysing federal tax appeals, and the Brazilian Federal Regional Court have issued decisions, favouring the Brazilian Revenue Service (BRS), over the resale minus method (RMM) for calculating a transfer pricing adjustment. March 09, 2011
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One of the largest automobile companies in the world has closed the book on a long-winded transfer pricing battle, which dates back to the mid-1990s. March 09, 2011
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The Mumbai Income Tax Appellate Tribunal (ITAT) has ruled that a taxpayer’s past transactions cannot be used as a comparable uncontrolled price (CUP) for the purpose of benchmarking a transaction. March 02, 2011
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The Court of Appeal has ruled that UK thin capitalisation legislation is compatible with EU law, overturning a previous decision, on appeal from HM Revenue & Customs (HMRC). February 28, 2011
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The Delhi Income Tax Appellate Tribunal (ITAT) has ruled that transfer pricing provisions do not apply if the assessee is not subject to tax in India. February 16, 2011
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The Supreme Tax Court in Germany has clarified that not only did the country’s old thin capitalisation rules not comply with the freedom of establishment provision of the European Community (EC) treaty, but they also infringed the non-discrimination clause of treaties relating to companies resident in non-EC countries. January 19, 2011
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In a decision that represents binding case law, the Supreme Administrative Court in Finland has delivered a ruling on the determination of arm’s-length rate of interest in intra-group financing structures. January 19, 2011
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Rohan Phatarphekar and Manish Bafna, of KPMG, dissect the Mumbai ITAT ruling in the case of Serdia Pharmaceuticals and explain why APIs can constitute a comparable uncontrolled price (CUP) for the import of drugs when the patent has expired. January 19, 2011
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Nidera, an Argentine grain producer and distributor, is being investigated by the Argentine revenue authority (AFIP), after being accused of transfer pricing manipulation. January 12, 2011
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In light of several recent developments in Indian transfer pricing, Rohan Phatarphekar
and Vinita Chakrabarti, of KPMG, provide an overview of key cases and legislation.
January 05, 2011
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Canada’s Federal Court of Appeal (FCA) has dismissed the Crown’s appeal in the GE Capital Canada (GECC) transfer pricing dispute over the payment of a guarantee fee by a subsidiary to its parent. January 05, 2011
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Boston Scientific, an international producer of medical devices, announced on Tuesday that the Internal Revenue Service (IRS) in the US has issued the corporation with a notice of deficiency, outlining unpaid taxes and interest.
January 05, 2011
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Cristiane M. S. Magalhães and Iara M. S. Sousa do Amaral of Machado Associados explains why a decision of the Federal Regional Court of Appeals of the 3rd region (TRF) may become an important precedent for transfer pricing in Brazil. December 13, 2010
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The Delhi Income Tax Appellate Tribunal upheld, in the case of Abhishek Auto Industries, the company’s arm’s-length justification of the payment of a royalty fee for technical know-how and assistance to a manufacturing entity. December 08, 2010
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In the Coca Cola India case the Supreme Court said that, because the writ position could not establish the facts of the case, the taxpayer must adopt proceedings before the assessing officer or transfer pricing officer. Hasnain Shroff and Rajan Iyer, of KPMG in Mumbai, analyse the case. December 01, 2010
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The Chinese tax authorities have formally signed the first automotive-related Mutual Agreement Procedures (MAP) completed in China, which is also the first successful MAP case in Guangdong Province. September 08, 2010
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A new circular telling local tax bureaux to carry out a nationwide evaluation of taxpayers’ 2008 and 2009 contemporaneous transfer pricing documentation (CTPD) was released on July 12 by the Chinese tax authorities. July 28, 2010
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Hasnain Shroff and Vinita Chakrabarti report on the Mumbai Tribunal’s ruling in the case of M/s Cheminova India Limited where a higher price paid to associated enterprises was accepted as the arm’s-length price, due to adequate commercial considerations. July 26, 2010
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A report on transfer pricing from the Joint Committee on Taxation (JCT) in the US has used private company information to outline case studies in a report which concluded that US rules are open to abuse. July 21, 2010
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Hasnain Shroff, Vinita Chakrabarti and Akash Arora discuss the Nimbus Communications Ltd Vs ACIT, Mumbai (ITA No.2361 (Mum.) of 2007) case and its implications for transfer pricing. July 20, 2010
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Companies adopt a wait and see attitude to Russia’s new transfer pricing rules. July 14, 2010
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Helga Marie Andresen and Merethe Bryn of Deloitte in Norway discuss the court’s ruling in the landmark case of ConocoPhillips, which shifted the tax authority’s approach to evaluating whether Norwegian companies receive their part of the profit compared to the group as a whole. July 12, 2010
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The company reported making a loss of A$107.9 million ($94 million) after being hit with a tax adjustment reportedly relating to intercompany transactions. July 12, 2010
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The Delhi High Court has issued a landmark ruling providing guiding principles on the applicability of the arm’s-length standard to the realm of marketing intangibles. July 12, 2010
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Fashion retailer, H&M, has been criticised for its operations in Bangladesh and tax payments amounting to transfer mis-pricing. July 07, 2010
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Gianmarco Monsellato and Sylvain Chevrier of Taj, a member of Deloitte Touche Tohmatsu, answer commonly asked questions about the implementation of the new French documentation rules. July 06, 2010
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Citrix Systems, a provider of IT solutions, has announced it has settled with the IRS in the range of $12 million to $15 million over disputes about transfer pricing and intellectual property transfers. July 06, 2010
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Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil. June 30, 2010
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The Federal Board of Revenue (FBR) in Pakistan believes pharmaceutical companies have used transfer pricing to evade Rp500 million ($5.8 million) in taxes. June 30, 2010
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An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
June 30, 2010
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The conclusion of a bilateral advance pricing agreement (APA) between the US and the Netherlands will allow FEI, a scientific instruments company, to release large valuation allowance and tax reserves from its accounts for the second quarter of 2010. June 28, 2010
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Fred O’Riordan, formerly with the CRA, talks about moving into the private sector and reveals his hopes for the future of arbitration between the US and Canada.
June 23, 2010
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Samir Gandhi, Manisha Gupta and Radhi Raman of Deloitte in India discuss the overzealous use of penalty provisions in the country. June 16, 2010
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Advisers report consistent attrition at Canada Revenue Agency (CRA) and this along with new initiatives and internal protocols is causing a severe backlog in audits and advance pricing agreement (APA) applications. June 09, 2010
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An Indian court has outlined the three criteria that taxpayers must satisfy to constitute a fixed place permanent establishment. June 09, 2010
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A mutual agreement has been settled between the competent authorities of the Netherlands and the US which amends the procedure by which US pension funds obtain an exemption from dividend withholding tax under the Netherlands-US tax treaty. June 02, 2010
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The Norwegian tax authorities recently won its overhead costs case against Enterprise Oil Norway (EO) in the Norwegian courts, because EO could not provide sufficient documentation to show that it had received the services that it had paid for. May 28, 2010
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Waman Kale and Vinita Chakrabarti report on a judgment by the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT) relating to the information technology, business process outsourcing sector. May 27, 2010
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Stefaan De Baets, First Attaché of Finances at the Belgian Finance Ministry, along with representatives from the country’s competent authority and the transfer pricing audit teams reveal how ECJ rulings may alter transfer pricing in the country. May 12, 2010
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Rahul Mitra and Navneet Kothari of PricewaterhouseCoopers in India call for transfer pricing experts to be mandatorily involved in Dispute Resolution Panels (DRP) decisions. May 11, 2010
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One of the world’s largest technology companies is challenging the Indian Directorate of Revenue Intelligence’s biggest claim to date. May 11, 2010
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TPWeek is updating its reader poll on the most aggressive tax authorities for transfer pricing. May 07, 2010
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Two companies that took on the tax authorities in the US and UK over transfer pricing issues, and achieved positive results, have now reported higher than expected earnings. May 04, 2010
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Hasnain Shroff and Vinita Chakrabarti report on an interesting case, where it was held that in order to determine the arm’s-length price of an international transaction, the arm’s-length margin should be applied only on the international transaction and not on the entire costs or sales of the taxpayer. April 26, 2010
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Toray Industries, a leading Japanese chemical manufacturer, has revealed it expects to receive a notice of correction based on transfer pricing issues raised by the Tokyo Regional Taxation Bureau. April 21, 2010
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Relying on the March 22 2010 decision in the Xilinx litigation case, Altera Corporation, a leader in reprogrammable logic devices, is confident it will not face the level of corporate tax it was expecting. April 21, 2010
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Gordon Hands of CUFTanalytics explains how taxpayers can assess the arm’s-length dividend rate for intercompany preferred share issuances. April 20, 2010
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The Danish tax authorities have collected DKK 15 billion ($2.8 billion) from transfer pricing audits of 32 multinational companies. April 15, 2010
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Batanayi Katongera of Olswang explores the practicalities of designing and implementing a dynamic global transfer pricing policy document. April 14, 2010
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Gordon Hands of CUFTanalytics examines two example cases, an interest rate swap and a factoring transaction, where expected loss (EL) is used to price the credit risk portion of the intercompany financial transaction. April 14, 2010
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India’s new dispute resolution panels (DRP) will continually adapt to a changing tax environment and greatly improve taxpayer litigation consistency, say two of the country’s leading advisers. April 13, 2010
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Polish taxpayers have been sent a strong warning after the country’s tax authorities confirmed that they will focus their 2010 audit work on transfer pricing and its associated issues. April 07, 2010
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Sanjay Sanghvi and Daksha Baxi discuss the landmark E*TRADE litigation and its implications for the India-Mauritius tax treaty. April 06, 2010
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Gordon Hands of CUFTanalytics discusses the merits of external credit ratings and forward-looking probability of default as credit risk measures when selecting comparable uncontrolled financial transactions (CUFTs) April 06, 2010
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The first-tier tax tribunal in the UK has cast doubt over the UK tax treatment of US limited liability companies (LLCs) in the decision Mr Swift v The Commissioners for HMRC ([2010] UKFTT 88 (TC)). March 31, 2010
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The US Court of Appeals for the Ninth Circuit has now affirmed the Tax Court's decision in the Xilinx case. March 22, 2010
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Hasnain Shroff, Sanjeev Gupta and Tarini Nijhara in India look at the unreported judgement in the case of IL Jin Electronics (India) Private Limited. March 15, 2010
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Ralf Heussner, Karl Gruendel, Chris Newman, and Kai Hielscher of the transfer pricing practice of Ernst & Young Shinnihon Tax in Tokyo discuss why Japan continues one of the most challenging jurisdictions for tax and transfer pricing in the world. March 09, 2010
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With increased audit activity and recent tax litigation in Canada, determining the arm’s-length pricing of guarantees continues to be a difficult transfer pricing issue and risk for multinationals. Gordon Hands of CUFTanalytics discusses the issues raised in the GE Capital Canada’s guarantee fee transaction litigation. March 01, 2010
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Amr El Monayer, assistant to the deputy minister of the Egyptian Ministry of Finance explains what the new guidelines will cover, and when they will be released. February 25, 2010
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The Mumbai Income Tax Appellate Tribunal has ruled that when determining the arm’s-length price of an international transaction, transfer pricing officers (TPO) must apply transfer pricing methods in accordance with the manner in which they are prescribed in the country’s transfer pricing rules. February 25, 2010
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A case that has just been decided in the Czech Supreme Administrative Court (SAC) provides an important discussion on transfer pricing methodology in disputes with the tax authorities in the context of the Czech tax law. February 23, 2010
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Phoenix Technologies has seen a bigger than expected revenue increase in the first three months of its financial year after settling a dispute with the Taiwan National Tax Administration (TNTA). February 17, 2010
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Hasnain Shroff and Poonam Ghelani in India look at the important VVF Limited case. February 16, 2010
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The Delhi bench of the Income-tax Appellate Tribunal held that interest-free loans advanced by Indian companies to their foreign affiliates do not comply with the arm’s-length standard. February 10, 2010
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The special bench of Chandigarh Income Tax Appellate Tribunal has restated the critical importance of conducting a detailed FAR analysis. February 04, 2010
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Indonesia’s head of transfer pricing has told a seminar of tax professionals the criteria used for initiating an audit, amid increased scrutiny from the country’s tax authorities. February 03, 2010
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The European Court of Justice (ECJ) has upheld a discrepancy in Belgium’s transfer pricing rules, even though it represents a restriction on the EU freedom of establishment. February 03, 2010
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Hasnain Shroff, A Pradeep and Vinita Chakrabarti of KPMG India discuss taxpayers' relief over finding out that the use of the new Indian dispute resolution mechanism is optional. February 02, 2010
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Hasnain Shroff and Vinita Chakrabarti of KPMG in India look at the Global Vantedge case. January 27, 2010
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Chemical company Innospec Limited has signed a £3.9 million ($6.5 million) agreement with HMRC in settlement of transfer pricing disagreements. January 18, 2010
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In a recent ruling in the case of Gharda Chemicals Limited, interesting questions were raised before the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT), the second appellate and the last fact finding authority in Indian judiciary. January 12, 2010
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A new software product could revolutionise the often lengthy and expensive process of translating transfer pricing documentation. January 07, 2010
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Google, the internet search and software company, should expect an investigation from the UK tax authorities after it used transfer pricing to avoid corporation tax, a leading specialist has said. January 06, 2010
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Samir Gandhi, Manisha Gupta and Viswanathan Subramaniam of Deloitte India explain the importance of maintaining appropriate documentation to evidence that the transaction price has been computed in good faith and with due diligence. October 29, 2009
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The company was given leave to file a reply in answer to the commissioner for Internal Revenue’s response to the petition for a rehearing. October 14, 2009
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In general, extensive documentation has to be prepared to demonstrate the application of the benefit test. Will the EU Joint Transfer Pricing Forum provide guidance for simplifications? October 06, 2009
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The US tax authorities have unsettled creditors of bankrupt telecommunications equipment provider, Nortel, by submitting a $3 billion claim for back taxes, interest and other penalties September 08, 2009
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In recent tax audits, several companies in Vietnam have seen challenges relating to transfer pricing. September 01, 2009
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What does the introduction of advance pricing arrangements mean for taxpayers in India? September 01, 2009
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In a series of amicus briefs filed with the US Court of Appeals for the Ninth Circuit, several powerful groups have expressed their support for Xilinx in the latest phase of its battle with the Internal Revenue Service. August 25, 2009
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An important concession helpful to manufacturers using mainland China contract processors has been denied. August 19, 2009
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What modifications to transfer pricing documentation for 2008 can distribution companies consider to reflect the impact of the economic downturn? August 17, 2009
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Xilinx has filed for a rehearing or a hearing en banc in the latest development in this historic case. August 13, 2009
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My company is planning to move some operations to Brazil, what are the key transfer pricing considerations in the country? August 11, 2009
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Lucia Fedina, Justen Ghwee, Juliane Keppler, and Gus Lee, of KPMG discuss how the global financial crisis has affected asset management transfer pricing. August 05, 2009
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Businesses are paying for less external advice as they try to save money during the economic downturn. Some have turned to software to help with transfer pricing documentation. July 28, 2009
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A proposal from the Netherlands government makes it even more important for companies to have sufficient documentation in place to support the arm’s-length nature of inter-company financial transactions between Dutch and non-Dutch group companies. July 22, 2009
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The Swedish Administrative Court of Appeal has upheld a lower court decision clarifying the determination of the arm’s-length interest rate for intercompany loans in a case involving one of the country’s largest real estate companies. July 15, 2009
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A Polish contract manufacturer for Plastic AG, a German entrepreneur, delivers the final goods directly to a customer. Now Polish SA takes over and invoices the customer. Does this trigger any German taxes? July 08, 2009
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A ruling by the Pune tribunal says that the revenue authorities in India must clearly demonstrate the appropriateness of a particular method when trying to make an adjustment based on the taxpayer's method choice. Vineet Chhabra and Viswanathan Subramaniam of Deloitte explain. July 02, 2009
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We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation? July 01, 2009
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Following a recent Indian tribunal ruling on the use of cash profit/sales, Samir Gandhi and Vineet Chhabra of Deloitte India explain the importance of profit level indicators (PLI) under the TNMM. June 24, 2009
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The Amsterdam Court of Appeals hands victory to the taxpayer in a transfer of goodwill dispute, limiting the taxes payable. Eduard Sporken, and Jenny Theresia of KPMG discuss the case and its implications. June 23, 2009
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Danny Beeton and Hannah Carter of Grant Thornton in the UK explain how the decision in the DSG case is potentially a turning point in transfer pricing economics, at least in the UK June 17, 2009
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What is the biggest change for companies operating in Mexico following the introduction of the new annual tax return form? June 15, 2009
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Cristiane Magalhães and Fábio Lima da Cunha of Machado Associados in Brazil report on how the authorities have been using information not accessible to taxpayers to determine arm’s-length prices.
June 15, 2009
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Following the conclusion of HM Revenue and Customs first major successful transfer pricing dispute, UK taxpayers are being warned that the authorities are thirsty for more. June 10, 2009
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The CRA has a reputation for being aggressive. What is the best way to avoid disputes? Or handle them if they arise? June 10, 2009
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What documentation do I need to prepare and file by what time for entities in Taiwan? June 04, 2009
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My company has entities in South Korea. What are the documentation requirements for those entities? May 27, 2009
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The US Internal Revenue Service (IRS) is battling the UK-based pharmaceuticals company GlaxoSmithKline over a potential $1.9 billion in back taxes, interest and penalties. May 27, 2009
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My company has entities in China. What documentation requirements do I have to fulfil, and when? May 18, 2009
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A decision by the Massachusetts Appellate Tax Board (ATB) has sent a warning to state tax auditors not to overreach in assessments related to inter-company pricing of services and products provided between companies and their out-of-state affiliates.
May 14, 2009
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Two cases before the Tax Court of Canada relate to financial transactions meaning taxpayers with intercompany financial transactions should be prepared for greater scrutiny under newly introduced reporting requirements. May 13, 2009
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The Australian Taxation Office has issued a new interpretative decision that highlights important tax issues facing foreign resident taxpayers leasing substantial equipment in Australia. May 06, 2009
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In India, the advance ruling in the case of Canoro Resources addresses the applicability of domestic anti-avoidance provisions to transfers between partners and foreign partnerships. April 29, 2009
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A recent court ruling has determined that disputes dealing with the attribution of profits to permanent establishments in India should not be heard by the high court, as the country’s tribunals will have the final say on the matter April 29, 2009
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Car maker Chrysler is closer to a strategic alliance deal with Fiat SpA after eliminating a transfer pricing hurdle that had threatened the process. April 29, 2009
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Exports made by a Brazilian company to offshore companies controlled by it, carried out in accordance with Brazilian transfer pricing rules, are analysed from a substance over form approach and regarded as sham transactions. April 29, 2009
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The Danish tax authorities are demanding DKr3.6 billion ($637 million) in back taxes from a multinational company that it claims used aggressive transfer pricing to avoid paying the proper amount of tax April 15, 2009
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An Indian tax tribunal has ordered a Belgian drug company to rethink its transfer pricing methods for transactions with its Indian subsidiary, despite referring the case back to the transfer pricing officer. April 08, 2009
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American Apparel has told investors that its effective tax rate decreased in the fourth quarter of 2008 because of changes to its transfer pricing policy March 25, 2009
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A Turkish construction company has won a case in Russia over when a permanent establishment (PE) is created.
March 19, 2009
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The poor state of the economy has led US advance pricing agreement (APA) program officials to become more open to modifying current and prospective APAs. However, no agreements have been changed yet. March 19, 2009
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New Zealand’s Inland Revenue Department (IRD) has followed through on its threat to get tough on transfer pricing and has warned businesses that they will be investigated if they fail to comply. March 18, 2009
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Japan remains one of the most challenging tax jurisdictions, with transfer pricing enforcement being a focal point of the Japanese tax authorities. Both foreign and Japanese multinationals face increasing scrutiny and a heightened risk of transfer pricing audits and potential adjustments, explain Karl Gruendel and Rolf Heussner of Ernst & Young Shinnihon Tax. March 16, 2009
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Under long-anticipated regulations published by the US Internal Revenue Service (IRS), cost sharing arrangements (CSAs) remain an effective tool that multinational taxpayers can use to efficiently develop and manage ownership of valuable intangible property among subsidiaries. But valuations of pre-existing, platform intangibles contributed to CSAs will be scrutinised by the IRS going forward March 12, 2009
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Taxpayers in China will need to ensure thorough documentation is in place for all transfer pricing after the authorities announced they will be tracking such filings electronically, making monitoring the information and pinpointing companies for audit easier. March 10, 2009
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Updated transfer pricing rules released on February 20 place a significant burden on both taxpayers and practitioners, beginning with the calendar year 2008. March 04, 2009
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An Indian automotive company has lost its appeal against the Indian transfer pricing authorities over the method used for carrying out transactions with its various entities. February 25, 2009
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A tribunal in India has ruled that payment of the arm’s length price to a dependent agent does not remove the tax liability of a foreign entities’ permanent establishment in India. February 25, 2009
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Reliance on on the applicable federal rate (AFR) safe haven of section 1-482.2 of the Internal Revenue Code is not likely to address the need to comply with both US transfer pricing regulations and the expectation of the foreign tax authority that the interest rate on the intercompany loan be consistent with market interest rates for comparable loans February 24, 2009
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The Indian division of Bunge, a US food company, has been ordered to pay additional taxes due to a transfer pricing-related indiscretion. The Indian income tax authority has said the company may also face a penalty for concealment of income January 27, 2009
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A tax dispute between global pharmaceutical firm, AstraZeneca, and HM Revenues and Customs (HMRC) has been deferred until April 2010, with the outcome of the case expected to have an impact on multinationals and their transfer pricing regimes.
January 20, 2009
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An important decision by the High Court orders transfer pricing offices to conduct new assessments for several taxpayers. January 09, 2009
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An Indian court has ruled that Coca-Cola India failed to apply transfer pricing rules following an agreement to offer advisory services to a related party. January 07, 2009
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Tax authorities around the world are beginning to note the importance of looking at both transfer pricing and customs valuations when assessing multinational companies’ operations. January 06, 2009
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Taxpayers may have to explain why they used a certain exchange rate in related-party transactions. If they cannot they could face higher tax bills, explain Jarosław Bieroński and Bartłomiej Biały of Sołtysiński Kawecki & Szlęzak December 23, 2008
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On July 17, the OECD issued its final report on the attribution of profits to permanent establishments, reaffirming the “separate entity approach” that hypothesises a permanent establishment (PE) as a separate and distinct enterprise that may deserve additional compensation according to the arm’s-length principle. The report notes, say Brandon Feldman and Patrick Breslin of the Ballentine Barbera Group, that the OECD transfer pricing guidelines should apply in such cases. December 16, 2008
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The Bangalore Tax Tribunal has ruled in favour of the taxpayer in a dispute that covered the powers of a transfer pricing officer to disregard a company’s transfer pricing analysis.
September 30, 2008
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Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process September 02, 2008
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Glenn DeSouza, managing director, TP Management Consulting, Shanghai, and Benjamin Cheong, intellectual property group, Baker & McKenzie, Hong Kong believe you have to consider the tax implications when seeking to protect your intellectual property in China August 13, 2008
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A new report, yet to be published by the European Commission, shows that the number of open cases in the Arbitration Convention (AC) is rising rapidly. The report which has been supplied to TP Week.com lists more than 350 cases.
August 07, 2008
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Stuart Edwards of PricewaterhouseCoopers, Australia, believes courts will favour traditional transactional transfer pricing methods rather than bottom line profits methods in the wake of the landmark Roche decision. July 30, 2008
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KR Girish and Himanshu Patel, of TP Week.com correspondent KPMG in India, believe the Authority for Advance Rulings was correct to use the narrow definition of fee for technical services under the double tax treaty with Singapore to decide the Cushman & Wakefield case in favour of the taxpayer July 24, 2008
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Denso Corporation has revealed that Japanese tax authorities have demanded about ¥7.3 billion ($68 million) in transfer pricing surcharges from the company July 09, 2008
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PricewaterhouseCoopers Canada outlines the main points in the Glaxo Canada ruling June 19, 2008
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CRA loses case to gain access to details on financial transactions June 19, 2008
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Medical devices business faces higher tax bill over Irish subsidiary June 12, 2008
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Transfer pricing at the heart of alleged state losses of $63 million June 12, 2008
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Pharmaceuticals company could face massive tax bill
June 12, 2008
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Speaking of the controversial IRS win in the US Court of Appeals for the Ninth Circuit in the Xilinx case, IRS commissioner Douglas Shulman called the decision a “real victory”. June 04, 2008
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TP Week correspondent KPMG explains the thinking behind the recent Foster’s case in before the Authority for Advance Rulings in India May 29, 2008
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Inter-company services charges again under the transfer pricing spotlight May 27, 2008
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Takashimaya hits transfer pricing troubles over Singapore business April 21, 2008
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Kim Jarrett and Mark Cormack of KPMG New Zealand contrast the tax authorities’ divergent approaches in Australia and New Zealand April 04, 2008
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H Ching Tan and Douglas Fone, of Transfer Pricing Associates, examine the transfer pricing issues in funding for Chinese enterprises March 25, 2008
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TP Week correspondent Machados explains why the easiest transfer pricing method is not always the best approach February 29, 2008
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Comprehensive order issued this week to implement documents law February 21, 2008
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Kishore Nair, of TP Week correspondent KPMG, reports that 72% of TNMM cases are selected for audit February 19, 2008
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Artur Klesk, head of transfer pricing at Accreo Taxand, a leading Polish TP commentator, discusses the fortunes of the APA initiative February 14, 2008
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Mario Ortega Calle, of TP Week correspondent Garrigues, explains how the regulation of intra-group expenses has changed February 13, 2008
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Andreas Köster-Böckenförde , of Jones Day in Frankfurt, explains the thinking behind recent revisions to TP law February 05, 2008
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TP Week correspondent Machado Associados reports on a key ruling by the Brazilian tax authorities January 24, 2008
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PricewaterhouseCoopers interprets recently updated rules January 19, 2008
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DJ Yeo, Stefan Moller and TY Nam, of TP Week correspondent Kim & Chang outline the thinking behind Korea’s TP policy January 16, 2008
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Bottled water company clashes with Pacific nation revenue authority over $3 million a week in exports January 13, 2008
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Glenn DeSouza, managing director, TP Week correspondent Transfer Pricing Management Consulting (TPMC), an allied firm of Baker & McKenzie January 09, 2008
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KPMG, TP Week’s correspondent in India, comments on why TNMM is the preferred TP methodology in India. Hardev Singh reports January 09, 2008
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Pre Budget wish list calls for exemption on TP issues January 03, 2008
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John Hobster, Ernst & Young’s head of global accounts, transfer pricing talks to TP Week about the key messages from the firm’s global TP report January 03, 2008
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Deloitte in Turkey reports on key developments in Turkey’s transfer pricing policy January 03, 2008
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TP Week published its list of most aggressive tax authorities list last week. The No 10 position was occupied by the HMRC December 20, 2007
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India’s leading software trade body supports early move December 18, 2007
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TP Week correspondent Taj conducts a survey of 430 decision-makers in companies in France December 18, 2007
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TP Week correspondent KPMG explains the Delhi Tax Tribunal ruling on Rolls Royce December 13, 2007
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John Nash, chief adviser to New Zealand’s Inland Revenue, writes exclusively on its transfer pricing policy December 11, 2007
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Politicians and lobbyists are calling for tougher transfer pricing rules – especially in the oil sector – in the Philippines. December 11, 2007
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Indian consultancies are facing a major shortage of transfer pricing specialists. December 11, 2007
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Mark Atkinson, head of transfer pricing for Deloitte UK, writing exclusively for TP Week, analysies its impact December 11, 2007
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UK revenue issues statement of practice and model agreement December 06, 2007
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In its first poll of senior tax directors, transfer pricing directors and advisers, TP Week reveals its definitive list December 06, 2007
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Carpet manufacturer Feltex collapses amid claims it is New Zealand’s Enron December 05, 2007
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Italy’s tough TP policy encourages more corporate deals. PwC reports December 05, 2007
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Ameriprise Financial, a US financial planning company, announced yesterday that it had changed its TP methodology December 04, 2007
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TP Week sponsor KPMG reports exclusively from a meeting with the revenue body and the Big Four. KR Girish and Veena Parrikar write December 03, 2007
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In the first of a series, Carol Todd of KPMG New Zealand, looks at customs valuation in her home country November 29, 2007
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In an exclusive article, Todd Miller and Michael Friedman, of McMillan Binch Mendelsohn in Toronto, analyse the transfer pricing implications of the protocol November 22, 2007
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East African government seeks to avoid transfer pricing on oil imports November 21, 2007
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The Belgian tax authorities have reformed the state's dispute resolution approach. PwC reports. November 19, 2007
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PricewaterhouseCoopers comments on the transfer pricing policy of the German tax authorities November 12, 2007
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There has been considerable criticism that India fails to accord with OECD guidelines on TP policy. Hardev Singh of KPMG South India argues that it does November 08, 2007
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Bob Reynolds reports on the explosive growth in transfer pricing for intangibles in Asia Pacific November 08, 2007
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Bob Reynolds reports on a case which will have widespread implications for companies November 08, 2007
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KR Girish and Rohit Jain, of KPMG in South India, review the Supreme Court verdict in Morgan Stanley November 08, 2007
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Income Tax Department appeals decision on captive November 08, 2007
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José Luis Gonzalo, Ramón Palacín, Juan José Terraza, Carlos Gabarró, Eduardo Sánchez and Vanessa Hernández of Ernst & Young in Spain analyse the regulations take effect in 2008 November 01, 2007
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The Income Tax department says Indian companies can enjoy same benefits as US companies November 01, 2007
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PwC reports on Ireland's approach to transfer pricing regulation October 31, 2007
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Finland introduced new transfer pricing legislation, says PwC October 31, 2007
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PwC describes how the Spanish government has taken its transfer pricing approach up a step October 31, 2007
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Belgium's transfer pricing regime has become stricter, reports PwC October 31, 2007
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Short deadlines characterise transfer pricing audits October 31, 2007
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HMRC wants to be seen as arbiter of best practice, says PwC October 31, 2007
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A radical revision of transfering pricing policy in Germany is described by PwC October 31, 2007
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PwC analyses the regulation of transfer pricing in key European markets October 31, 2007
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James Gatley, of KPMG in Toronto analyses the recent Hallmark Cards ruling October 30, 2007
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In the first part of an interview with TP Week, Roy Warden, one of the senior members of HMRC’s transfer pricing management, looks at the challenges ahead
October 19, 2007
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Theo Elshof and Pim Gerritsen van der Hoop, of Deloitte in the Netherlands, writing exclusively for TP Week, examine the TP priorities for the Dutch tax authorities October 17, 2007
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Pan-European Group begins focus on transfer pricing implications of business reorganisations October 17, 2007
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Ed Kroft and Deborah Toaze, of McCarthy Tétrault, explain the Canadian Revenue Agency ‘s focus on TP audits October 12, 2007
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K R Girish and Veena Parrikar, of KPMG, question one solution fits all for companies seeking transfer pricing savings from shifting activities offshore October 08, 2007
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Global risk management in relation to tax and transfer pricing is becoming a top priority for both CFOs and heads of tax of multinational corporations. Michel Sijmonsbergen, Steven Carey and Carsten Schmid of Transfer Pricing Associates look at the key trends October 08, 2007
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The UK tax authorities are changing the way they deal with transfer pricing. So International Tax Review presents the findings of a major and timely survey of corporate taxpayers on this increasingly important subject. October 08, 2007
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Rosa María Gil and Diego González-Béndiksen of Baker & McKenzie explain how transfer pricing rules have developed in Ecuador since they were introduced more than two years ago October 08, 2007
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Rene Fleming and Sandra Goldberg of Deloitte in Ottawa comment on binding arbitration in the long-awaited Canada-US protocol October 08, 2007
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SS Palwe, Samir Gandhi, Tehmina Latiwala and Mital Patel of Deloitte in Mumbai comment on a key transfer pricing ruling October 08, 2007