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
|