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2011

Issue

Date

Subject

2011-51

August 26, 2011

  • China: Jiangsu provincial tax administration’s training focuses on transfer pricing issues; liquid crystal display, battery, communications, and related industries targeted
  • 2011-50

    August 25, 2011

  • Indonesia: Tax audits to focus on related-party transactions, among other items
  • 2011-49

    August 15, 2011

  • United States: State tax implications of transfer pricing issues
  • 2011-48

    August 10, 2011

  • Canada: 2011 report card on CRA’s mutual agreement program
  • 2011-47

    August 8, 2011

  • India: No transfer pricing adjustment when period for payment, basis for computation of royalty materially differ from those for comparable transactions
  • Taiwan: Regulations address assessment of interest expenditure on related-party debts
  • 2011-46

    July 27, 2011

  • United States: IRS announces reorganization of transfer pricing functions
  • 2011-45

    July 26, 2011

  • Brazil: Guidance Addresses Application of Transfer Pricing Rules to “Back-to-Back Transactions”
  • India: Tribunal Upholds Transfer Pricing Adjustment Based on Comparable Import Price Obtained From Customs Data
  • 2011-44

    July 25, 2011

  • Turkey: First Unilateral APA Is Concluded
  • 2011-43

    July 15, 2011

  • Malaysia: Tax Authorities Focus on Enhanced Transfer Pricing Compliance
  • 2011-42

    July 14, 2011

  • India: Continuing Debit Balance in Accounts of Associated Enterprise Not an “International Transaction” and Appropriate Allocation of Costs Between Entities
  • 2011-41

    July 13, 2011

  • Russia: Final Reading of Draft Transfer Pricing Law; Possible Taxpayer Action Steps Prior to Enactment
  • 2011-40

    July 11, 2011

  • United States: Transfer Pricing Audits and Taxable REIT Subsidiaries: Considerations and Cautions
  • 2011-39

    July 8, 2011

  • India: Loss-Making Companies Cannot Be Rejected Simply on the Basis of Losses, but Can Be Excluded Under Other Comparability Aspects
  • India: Arm’s Length Price for Interest on Extended Credit to U.S. Associated Enterprise Is Determined Based on U.S. Dollar LIBOR, and Not on Any Other Currency-Denominated Loan Rate
  • 2011-38

    June 30, 2011

  • India: Advance Pricing Agreement Considerations for India
  • 2011-37

    June 28, 2011

  • India: 2009 Amendment to Transfer Pricing Rules Concerning +/- 5% Variation Applies Prospectively—Not Retroactively
  • India: Arm’s Length Price of Royalty Payments Cannot Be Determined to Be “Zero” Merely Because Taxpayer Incurred Losses
  • 2011-36

    June 20, 2011

  • World Customs Organization: Converging Transfer Pricing and Customs Valuation Rules
  • 2011-35

    June 17, 2011

  • Argentina: New Provision Requires Annual Filing of Additional Transfer Pricing Return (Form F.969)
  • 2011-34

    June 13, 2011

  • OECD: Multi-Country Analysis of Existing Transfer Pricing Simplification Measures
  • 2011-33

    June 9, 2011

  • Australia: Full Federal Court of Australia Upholds That Taxpayer Had Proved That Prices Paid by It Were Less Than Prices Paid for Independent Comparable Purchases; Focus on Identifying True Comparable Data
  • India: Once the Transfer Pricing Officer Has Accepted the Arm’s Length Nature of Royalty Payments, the Assessing Officer Cannot Examine the Reasonableness of the Expenditure
  • 2011-32

    June 8, 2011

  • Denmark and China: Third Bilateral Advance Pricing Agreement Is Signed
  • 2011-31

    June 6, 2011

  • Canada: Examining the Tax Court of Canada’s Decision: Taxpayer’s CUP Prevails Over Canada Revenue Agency’s Profit-Based Approach
  • The Netherlands: Dutch Revenue Concluded 205 APAs in 2010
  • 2011-30

    June 1, 2011

  • India: Tribunal Finds Existence of Actual Cross-Border Transaction and Motive to Shift Profits Outside India, or to Evade Taxes, Not Pre-Conditions for Transfer Pricing Provisions to Apply
  • 2011-29

    May 18, 2011

  • Russia: OECD Addresses Proposed Revisions to Russian Federation’s Transfer Pricing Law
  • 2011-28

    May 11, 2011

  • Canada: Application of CUP Method and Other Transfer Pricing Issues Addressed by Tax Court of Canada
  • India: Tribunal Holds When Loss-Making Companies Are Taken Out of the Comparables’ Set, “Super Profit-Earning Companies” Also Must Be Removed
  • 2011-27

    May 9, 2011

  • OECD Model Tax Convention: Discussion Draft on the Meaning of “Beneficial Owner”
  • 2011-26

    May 4, 2011

  • Mexico: Transfer Pricing Audits of Maquiladoras
  • 2011-25

    April 26, 2011

  • The Netherlands: Dutch Tax Agenda—Observed From a Transfer Pricing Perspective
  • 2011-24

    April 14, 2011

  • KPMG Report: Asia Transfer Pricing Review
  • 2011-23

    April 13, 2011

  • KPMG Report: A World in Transition: Managing the Transfer Pricing Implications of Complex Supply Chains
  • 2011-22

    April 12, 2011

  • Luxembourg: Additional Guidance for Companies Regarding APAs and Intra-Group Financing Transactions
  • 2011-21

    April 4, 2011

  • Australia: New Guidelines for the Advance Pricing Arrangement (APA) Program
  • 2011-20

    March 30, 2011

  • United States: IRS Chief Counsel Advice Addresses Valuation Theories Contained in IRS’s Cost Sharing Buy-in Coordinated Issue Paper
  • 2011-19

    March 29, 2011

  • United States: IRS Reports an Increase in APA Applications Filed for 2010
  • 2011-18

    March 10, 2011

  • KPMG’s Global Transfer Pricing Review—2011 Edition
  • 2011-17

    March 9, 2011

  • Norway: Court Holds Marketing Activities of Norwegian Subsidiary Constitute Permanent Establishment of Irish Sales Company, and Allocates Profits for Norwegian Tax Purposes
  • 2011-16

    March 4, 2011

  • Portugal: Increased Focus on Transfer Pricing Audits and Disclosures
  • 2011-15

    March 2, 2011

  • India: Transfer Pricing Officer’s Determination Is Restricted to Determining Arm’s Length Price of Only Those Transactions Referred by the Assessing Officer
  • India: Recovery of Pre-Commencement Costs
  • 2011-14

    February 21, 2011

  • Brazil: Recent Court Decisions Address Constitutional Issues Concerning the Resale Price Method
  • 2011-13

    February 18, 2011

  • Norway: Tax Authorities Announce Transfer Pricing Adjustments of NOK 9 Billion (US $1.5 Billion / €1.1 Billion) for 2009
  • United Kingdom: HMRC’s Approach on the Use of MAP and/or Arbitration Procedures
  • 2011-12

    February 17, 2011

  • Australia: Final Taxation Ruling on Transfer Pricing and Cross-Border Business Restructures
  • India: Methodology to Be Used in Valuing Assets with Respect to the Transfer of a Business as a Going Concern
  • 2011-11

    February 14, 2011

  • Spain: Increased Audit Scrutiny of Transfer Pricing Transactions
  • 2011-10

    February 9, 2011

  • The Netherlands: Guidance on Attribution of Profits to Permanent Establishments
  • 2011-09

    February 8, 2011

  • Russia: Court Holds Taxpayer Cannot Rely on Benchmarking Study, Based on Financial Information From International Database
  • 2011-08

    February 1, 2011

  • India: “Supernormal” Profit-Making Companies Are to Be Excluded From Comparables
  • OECD: Committee on Fiscal Affairs Approves Scope of Project on Transfer Pricing Aspects of Intangibles
  • 2011-07

    January 31, 2011

  • European Commission: Update on Work of the EU Joint Transfer Pricing Forum Concerning Low-Value-Adding Intra-Group Services and Potential Approaches to Non-EU Triangular Cases
  • 2011-06

    January 28, 2011

  • Brazil: New Guidance Provides Safe Harbor for Eligible Exporters with Respect to Export Prices for Transactions with Related Parties
  • Luxembourg: Guidance on Application of Transfer Pricing Rules to Companies Regarding Intra-Group Financing Transactions
  • 2011-05

    January 26, 2011

  • European Commission: Report of Responses Received in Connection with Consultation on Income Tax Treaties and Cases of Double Taxation
  • 2011-04

    January 19, 2011

  • Brazil: Relief Provided for Export Prices FY 2010 to Account for Brazilian Currency Appreciation
  • India: Benefit of 5% Variation Not Available If There Is Only One Uncontrolled Price
  • 2011-03

    January 6, 2011

  • France: Guidance on Transfer Pricing Documentation Requirements Is Issued by the Tax Authorities
  • 2011-02

    January 5, 2011

  • Egypt: Transfer Pricing Guidelines
  • India: Price of Generic Active Pharmaceutical Ingredient May Constitute CUP for Determining Import Price of Branded Generic Drug After Expiration of the Patent
  • 2011-01

    January 4, 2011

  • China: Inaugural APA Report Examines Transfer Pricing Developments From 2005 Through 2009
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