Navigation Menu

Poll

Do you think country by country reporting is a good thing?

Yes
78%
No
22%


View previous poll results

Skip to Navigation menu Skip to top of page


Content

British industry calls on government to extend scope of patent box

The Confederation of British Industry (CBI) sent its submission to the Treasury today in anticipation of the 2012 budget. February 22, 2012

Pepsi fights Indian tax authorities over Rs1 billion

Pepsi Foods’ stay of application with the Indian legal system over a demand of Rs1.04 billion ($21 million) has been disposed by the Income Tax Appellate Tribunal (ITAT) but an appeal date has been set. February 21, 2012


Why country by country reporting is not compatible with transfer pricing realities

An estimated $110 billion disappeared because of transfer mispricing on the import of crude oil in the EU and US between 2000 and 2010, a recent report from Publish What You Pay (PWYP) Norway said. February 17, 2012

Common mistakes transfer pricing advisers make when dealing with the authorities

Your transfer pricing advisers provide the local link between your company and the tax officials working in every operational jurisdiction. An Italian revenue official explains the common mistakes advisers can make and how communications can be improved. February 16, 2012


New UK CFC rules put emphasis on significant people functions

The long-awaited draft UK controlled foreign companies (CFC) legislation was published in December 2011 with additional guidance and updated draft legislation issued on January 31 2012. The proposed rules affect transfer pricing by placing a new emphasis on significant people functions. February 15, 2012

BREAKING NEWS: The US budget and its TP implications

The Obama Administration released the proposed Fiscal Year 2013 Budget of the US government yesterday. Aaron Bone and Katherine Kimball, of Charles River Associates in San Diego, provide a commentary on its transfer pricing implications. February 14, 2012


UK concludes patent box consultation

The UK government has concluded its consultation on a proposed patent box. It is hoped it will encourage investment and economic growth in the UK and prevent innovative businesses moving intellectual property (IP) offshore. February 10, 2012

Belgium: Transfer pricing aspects of restructuring

By Isabel Verlinden, Sabine Wahl and Yoko Mondelaers of PwC Belgium. February 10, 2012


Why Maruca’s goal to select high-risk transfer pricing cases for the IRS may be difficult to achieve

Sam Maruca, the IRS’s transfer pricing director, said his highest priority was enforcement; to select the cases that need pursuing and to leave those that do not. One ex-IRS officer explains why this is easier said than done. February 09, 2012

How the transfer of routine activity could be subject to income tax

The French Court of Appeal will consider how the transfer of a routine activity can be subject to tax, through a transfer of benefits, in instances where no compensation is provided. February 09, 2012


OECD transfer pricing translation is next step to ensnaring Brazil

The OECD has translated the Transfer Pricing Guidelines for Multinational Enterprises into Portuguese, a next step in aligning the country with global best practice. February 07, 2012

How transfer pricing advisers are responding to changes in service demand

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


Why taxpayers should stop using residual pricing methods in Portugal

The Portuguese tax authority has turned its transfer pricing focus to residual pricing methods, meaning companies should stop using them if they want to save money. February 02, 2012


Taxpayers criticise Chinese regulations

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

OECD 2010 MAP statistics: Canada, Germany and Poland comment

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

Reed Elsevier explains its practical issues with IP

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

Choosing the profit level indicator in transfer pricing

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


Ceteris hires a managing director in Chicago

January 31, 2012

A new director Whipps up the UK KPMG team

The UK team has also undergone a number of internal changes. January 24, 2012

Mary Bennett's successor named

The new head of the OECD's tax treaty, transfer pricing and financial transactions division has been named. January 11, 2012

KPMG has new transfer pricing managing director

December 21, 2011

KPMG re-hires principal for economics and valuation practice

December 15, 2011

Westerburgen joins Baker & McKenzie

December 15, 2011


Why Dutch R&D deduction may cause inconsistencies with transfer pricing

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

Hong Kong to launch APA programme

The Hong Kong Inland Revenue Department (IRD) will launch an advance pricing agreement (APA) programme in April. January 09, 2012

Japanese tax reform to include earning stripping rules

The outline for Japanese tax reform proposals was released on December 26 2011 with changes to intercompany loan regulations. January 06, 2012

China unveils future for thin cap audits

China has underlined its determination to strengthen its anti-avoidance rules by concluding the country’s first thin capitalisation audit. January 03, 2012

Indonesia updates its transfer pricing regime

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


Clashes between customs and transfer pricing law highlighted in Korean case

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

Alberta Printed Circuits to be OECD example

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

Reed Elsevier explains its practical issues with IP

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

How Irish insurance firm profits are taxable for Dutch shareholders

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


Irish transfer pricing documentation guide

By Barbara Dooley and Gavan Ryle of PwC, Dublin. June 23, 2011

Ecuador transfer pricing documentation guide

Alexis Carrera, of Ernst & Young in Quito, reports on the distinctive documentation rules in Ecuador March 23, 2011

Canada transfer pricing documentation guide

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

China and Hong Kong transfer pricing documentation guide

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

Germany transfer pricing documentation checklist

Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime. March 08, 2010

Japan transfer pricing documentation guide

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

Egypt – Transfer Pricing Documentation Requirements

Anthony Mahon and Andy El Zayaty of Deloitte provide a guide to the transfer pricing requirements in Egypt. December 15, 2010

Singapore transfer pricing documentation guide

Edmund Leow, principal, Baker & McKenzie.Wong & Leow, describes documents requirements in Singapore. February 22, 2010

South Korea transfer pricing documentation guide

Tae-Yeon Nam, Dong-Jun Yeo and Stefan Moller, Kim and Chang, Seoul July 14, 2009

Argentina transfer pricing documentation guide

Diego Etchepare, Juan Carlos Ferreiro and Violeta Maresca, PricewaterhouseCoopers February 11, 2009


Double tax treaties and transfer pricing in Poland

Mike Ahern and Sebastian Lebda, of PricewaterhouseCoopers in Poland, discuss the relationship between tax treaties and transfer pricing June 03, 2008

Double tax treaties and transfer pricing in Ecuador

Alexis Carrera Reyes, of Ernst & Young in Quito, reveals key moves being taken in Ecuador to end treaty shopping June 05, 2008

Double tax treaties and transfer pricing in Brazil

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

Double tax treaties and transfer pricing in Peru

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

Double tax treaties and transfer pricing in India

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


How to survive a transfer pricing audit in India

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

How to survive a transfer pricing audit in Malta

Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta April 15, 2008

How to survive a transfer pricing audit in the Czech Republic

Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process April 07, 2008

How to survive a transfer pricing audit in China

Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit April 06, 2008

How to survive a transfer pricing audit in Poland

Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008

REGIONAL UPDATES

Click here for transfer pricing updates from around the world

GLOBAL TP RECRUITMENT