Issue

Date

Subject

2006-47

December 21, 2006

• IRS Clarifies Transfer Pricing Services Regulations; Effective Date Is Modified

2006-46

December 20, 2006

• Mexico: Documentation Requirements Concerning Transactions with Related Parties
• Poland: Changes for 2007 Include APAs for Permanent Establishments, Binding Rulings, and Transfer Pricing Documentation Rules
• Venezuela: Increased Scrutiny of Related-Party Transactions

2006-45

December 15, 2006

• Israeli Transfer Pricing Rules—2006

2006-44

December 11, 2006

• Spain: Changes to Transfer Pricing Rules Included in Recent Legislation

2006-43

December 4, 2006

• Belgium: New Transfer Pricing Guidance Released by Belgian Tax Authorities

Issue

Date

Subject

2006-42

November 29, 2006

• Canada: Valuation for Transfer Pricing and Customs Purposes; Clarification of “Reasonable Efforts” to Determine Arm’s Length Transfer Prices

2006-41

November 17, 2006

• IRS Revises Procedures for Requesting Competent Authority Assistance

2006-40

November 13, 2006

• Germany: Explanation of APA Bulletin Concerning Transfer Pricing Between Internationally Associated Enterprises

2006-39

November 9, 2006

• Norway: Draft Transfer Pricing Documentation Requirements Are Released

2006-38

November 6, 2006

• Germany: Tax Authorities Release New APA Bulletin

2006-37

November 3, 2006

• Asia/Pacific: Transfer Pricing in the Electronics Industry

Issue

Date

Subject

2006-36

October 31, 2006

• China: Recent Guidance Provides That Transfer Pricing Adjustments May Be Further Taxed as “Deemed Dividends”

2006-35

October 9, 2006

• Analysis of the New Temporary Regulations Concerning Transfer Pricing for Services and the Allocation of Income from Intangibles

Issue

Date

Subject

2006-34

September 20, 2006

• Poland: Proposed Changes to Transfer Pricing Rules

2006-33

September 11, 2006

• Glaxo Transfer Pricing Dispute Settled

Issue

Date

Subject

2006-32

August 31, 2006

• Finland: Transfer Pricing Documentation Requirements

2006-31

August 23, 2006

• Australia: Transfer Pricing Issues Subject to ATO Compliance Program 2006-07

2006-30

August 16, 2006

• Public Hearing Announced for Proposed Regulations on Intercompany Services Transactions and Allocation of Income from Intangibles

2006-29

August 10, 2006

• Transfer Pricing: 2006 Tax Reference Library

2006-28

August 1, 2006

• Discussion of Section 482 Regulations on Intercompany Services Transactions and Allocation of Income from Intangibles

Issue

Date

Subject

2006-27

July 31, 2006

• Text of Regulations on Treatment of Controlled Services Transactions Under Section 482 and Allocation of Income from Intangibles

2006-26

July 17, 2006

• Turkey: Recent Legislative Changes to the Transfer Pricing Rules

Issue

Date

Subject

2006-25

June 27, 2006

• EU Council Adopts Code of Conduct on Transfer Pricing Documentation

2006-24

June 6, 2006

• Thailand: Transfer Pricing Update

2006-23

June 1, 2006

• Canada: Update on Transfer Pricing Cases Pending Before the Courts

Issue

Date

Subject

2006-22

May 4, 2006

• Status of Transfer Pricing Enforcement in China

2006-21

May 1, 2006

• Revenue Procedure Updates Competent Authority Guidance for Tax Coordination Agreements Involving U.S. Possessions

Issue

Date

Subject

2006-20

April 28, 2006

• What Can Taxpayers Do Pending the Release of Transfer Pricing Documentation Rules in China?

2006-19

April 5, 2006

• South Africa’s Transfer Pricing Documentation Policy Is Clarified

Issue

Date

Subject

2006-18

March 31, 2006

• IRS Releases Its Annual APA Report for 2005

2006-17

March 27, 2006

• Canada Revenue Agency Provides Update on Referrals to Transfer Pricing Review Committee

2006-16

March 20, 2006

• Spain: Changes to Draft Transfer Pricing Rules Are Proposed

2006-15

March 17, 2006

• Canada Revenue Agency Reports on Its APA and Competent Authority Programs

2006-14

March 2, 2006

• Singapore: New Transfer Pricing and Advance Pricing Agreement Guidelines
• Vietnam: New Transfer Pricing Rules

Issue

Date

Subject

2006-13

February 28, 2006

• Ecuador: Tax Authority Issues Guidelines Implementing the Transfer Pricing Rules
• Mexico Makes Changes to Rules for Applying Transfer Pricing Methodologies

2006-12

February 24, 2006

• India: Presence of U.S. Company’s Employees in India Constitutes a Service PE; However, No Additional Income Is Attributable to Indian PE Because Subsidiary Was Remunerated at Arm’s Length Basis

2006-11

February 23, 2006

• M&A Raises Transfer Pricing Challenges and Opportunities

2006-10

February 17, 2006

• Croatia: New Transfer Pricing Compliance Requirements
• Denmark: Guidelines on Transfer Pricing Documentation

2006-09

February 8, 2006

• New Canada Revenue Agency Guidelines on Determining Permanent Establishment in Canada

2006-08

February 6, 2006

• Update of Transfer Pricing Developments in India

Issue

Date

Subject

2006-07

January 25, 2006

• Spain: Changes to Transfer Pricing Rules Are Proposed

2006-06

January 18, 2006

• France: Draft Instruction Could Provide Guidance Concerning Mutual Agreement Procedure and Elimination of Double Taxation of Related Enterprises

2006-05

January 17, 2006

• EC Proposes Home State Taxation Pilot Program to Address Cross-Border Issues of Small and Medium-Sized Companies

2006-04

January 12, 2006

• Update of Transfer Pricing Developments in China

2006-03

January 6, 2006

• Brazilian Provisions Offer Relief from Impact of Transfer Pricing Rules Relating to Certain Exports

2006-02

January 5, 2006

• Canadian Perspective: New Canada-United States Agreement on Competent Authority Disputes—Resolving Factual Disagreements

2006-01

January 4, 2006

• United Kingdom: Draft Guidance Focuses on VAT Implications of Transfer Pricing Adjustments

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