Issue |
Date |
Subject |
2009-76 |
November 18, 2009 |
France: Revised Transfer Pricing Documentation Requirements Could Apply for More Taxpayers
|
2009-75 |
November 16, 2009 |
India: Tribunal Holds Assessing Officer’s Adjustment Concerning International Transactions Was Not Justified When Transfer Pricing Officer Accepts Arm’s Length Character of the Transactions
New Zealand: What Transfer Pricing in the Recession Means for New Zealand Business
|
2009-74 |
October 29, 2009 |
Transfer Pricing Year-End Issues and Risks
|
2009-73 |
October 27, 2009 |
India: Penalty Proceedings Are Not Appropriate When Taxpayer Demonstrates Application of Good Faith and Due Diligence Standards Under the Transfer Pricing Rules
The Netherlands: Reports of APA Statistics
|
2009-72 |
October 22, 2009 |
Hungary: Changes to Transfer Pricing Documentation Rules Are Effective in 2010
|
2009-71 |
October 19, 2009 |
Belgium: New Reporting Requirements for Intercompany Transactions and Off-Balance Sheet Arrangements in Financial Accounts—New Tool for Selecting Taxpayers for Transfer Pricing Audits by Belgian Tax Authorities
|
2009-70 |
October 16, 2009 |
China: Transfer Pricing Implications of Recent Guidance Clarifying Tax Treatment of Royalty Payments
|
2009-69 |
October 14, 2009 |
Canada Revenue Agency Issues 2009 Report Card on Mutual Agreement Program
EC Proposal to Revise Code of Conduct for Applying Arbitration Convention to Improve Prevention of Double Taxation
|
2009-68 |
October 9, 2009 |
EU Joint Transfer Pricing Forum: Summary Report on Penalties
Sweden: Legislation Introducing an Advance Pricing Agreement Program
|
2009-67 |
September 30, 2009 |
Sweden: Advance Pricing Agreement Measures Included in Budget for 2010
|
2009-66 |
September 29, 2009 |
Austria: Recent Developments Include the Release of Draft Transfer Pricing Guidelines for Comments, and Supreme Tax Court Decision on Deductibility of Management Fees
OECD Proposes to Fine-Tune Transfer Pricing Guidelines
KPMG Report: Planning for the Recovery, Examining Transfer Pricing in the Current Environment and Beyond
|
2009-65 |
September 25, 2009 |
Germany: Tax Authorities Issue Clarifying Administrative Guidelines Relating to the Exit Tax Regime
Korea: National Tax Service Clarifies Contemporaneous Documentation Rules and Penalty Relief Relating to Transfer Pricing Adjustments
|
2009-64 |
September 21, 2009 |
Korea: Summary of the National Tax Service’s APA Report for 2008
|
2009-63 |
September 18, 2009 |
China: State Administration of Taxation’s Annual Nationwide Transfer Pricing Training; Focus on Pharmaceutical Sector
|
2009-62 |
September 16, 2009 |
Adjusting Pricing Methods for APAs in an Economic Downturn
Latin America: Tax Authorities’ Increased Focus on Transfer Pricing Issues
United States: The Services Regulations Go Final, but an Issue Lingers
|
2009-61 |
September 11, 2009 |
Taiwan: Recent Guidelines Relating to Cross-Border Service Charges
Venezuela: Tax Authority Makes Transfer Pricing Assessments, Imposes Substantial Penalties
|
2009-60 |
September 9, 2009 |
Denmark: New Valuation Guidelines Issued by the Danish Tax Authorities
|
2009-59 |
September 1, 2009 |
China: Tax Authorities Identify Transfer Pricing Audit Targets
|
2009-58 |
August 31, 2009 |
KPMG’s Global Transfer Pricing Review
|
2009-57 |
August 24, 2009 |
United States: Deadline for Filing Initial Cost Sharing Arrangement Statement Is September 2, 2009
|
2009-56 |
August 18, 2009 |
Vietnam: Tax Authorities Focus on Transfer Pricing Issues in Recent Tax Audits
|
2009-55 |
August 17, 2009 |
India: Details of Transfer Pricing Proposals in the Direct Tax Code Bill, 2009
|
2009-54 |
August 14, 2009 |
India: Overview of Transfer Pricing Proposals in the Draft of the Direct Tax Code
|
2009-53 |
August 12, 2009 |
Hong Kong: Court of Appeal Clarifies Availability of 50:50 Concession for Hong Kong Manufacturers Using Mainland China Contract Processors
|
2009-52 |
August 6, 2009 |
Turkey: Guidelines for Invoking Mutual Agreement Procedures in Connection with Income Tax Treaties
North and French-Speaking Africa: Countries Aim at Reinforcing Transfer Pricing Rules
IRS Issues Additional Directive on Intersection of Section 965 Repatriations, Transfer Pricing Adjustments
|
2009-51 |
July 31, 2009 |
United States: Text of Final Regulations on Intercompany Services Transactions and Allocation of Income From Intangibles Under Section 482
|
2009-50 |
July 27, 2009 |
China Expands Contemporaneous Documentation Requirements, Targets Multinationals
|
2009-49 |
July 24, 2009 |
Australia: Considering Transfer Pricing Issues in Connection with Customs Law
Greece: Transfer Pricing Documentation Rules Are Enacted into Law
|
2009-48 |
July 20, 2009 |
Poland: Draft Decree to Clarify and Reorganize the Rules Concerning Income Tax Assessment on Transactions Between Related Parties
|
2009-47 |
July 14, 2009 |
China and Denmark: First Bilateral Advance Pricing Arrangement
|
2009-46 |
July 8, 2009 |
India: Transfer Pricing Proposals in Indian Union Budget 2009-2010
|
2009-45 |
July 7, 2009 |
India: Tribunal Concludes Transfer Pricing Regulations Apply Even if Taxpayer’s Income Is Exempt From Tax, and That Method Adopted by Taxpayer Is Valid Unless Tax Authorities Can Show Another Method Is More Appropriate
|
2009-44 |
June 29, 2009 |
Greece: Tax Bill Concerning Transfer Pricing Documentation Rules and Other Provisions Is Pending Before Parliament
|
2009-43 |
June 26, 2009 |
United States: Federal Circuit Upholds Commerce Department’s Use of a Constructed Market Price in Applying the “Major Input Rule” for Goods Purchased From Related Companies
Financial Services: Transfer Pricing for Troubled Times
Hedge Funds and Private Equity Firms: The Big Squeeze
|
2009-42 |
June 24, 2009 |
Managing Transfer Pricing Risk
Taiwan: One-Time Transfer Pricing Downward Adjustment Is Allowed Under Certain Conditions
|
2009-41 |
June 22, 2009 |
India: Cash Profit/Sales or Cash Profit/Cost Can Be an Allowable Profit Level Indicator Under TNMM for Mitigating Differences in Asset Profile if Warranted Under the Circumstances
|
2009-40 |
June 18, 2009 |
Brazil: New Law Redefines Criteria of Tax Favorable Jurisdiction for Transfer Pricing Purposes
China: Tax Authorities to Focus on Related-Party Transactions of Companies Conducting Highway Operations
|
2009-39 |
June 11, 2009 |
Mexico: Extended Deadline, Reduced Scope of Additional Transfer Pricing Disclosure Requirements
|
2009-38 |
June 5, 2009 |
Colombia: Change in Tax Administration’s Organizational Structure Expected to Result in Increased Audits of Taxpayer Compliance with Transfer Pricing Documentation Rules
|
2009-37 |
June 2, 2009 |
India: Transfer Pricing Provisions Have Precedence Over General Capital Gains Measures in Certain Situations Involving International Transactions
|
2009-36 |
May 28, 2009 |
2009 Transfer Pricing Asia/Pacific Guide
|
2009-35 |
May 27, 2009 |
United States: Initial Discussion of Ninth Circuit’s Decision in Xilinx Case
|
2009-34 |
May 27, 2009 |
United States: Text of Ninth Circuit’s Decision in Xilinx Case
|
2009-33 |
May 26, 2009 |
China: Guidelines Aim to Assist Large Enterprises in Managing Their Tax Risk, with a Focus on Tax Compliance Duties and Responsibilities
|
2009-32 |
May 20, 2009 |
South Africa: Interaction Between Transfer Pricing and Exchange Control Rules Concerning Interest on Foreign Loans
|
2009-31 |
May 19, 2009 |
France: Update on Status of Legislation That Would Introduce Transfer Pricing Documentation Rules for French Companies
|
2009-30 |
May 18, 2009 |
Hong Kong: New Guidelines for Relief From Double Taxation Due to Transfer Pricing or Profit Reallocation Adjustments
|
2009-29 |
May 14, 2009 |
United Kingdom: First Special Commissioners' Transfer Pricing Case to Consider Pricing Methodology
|
2009-28 |
May 13, 2009 |
Transfer Pricing in a Recession
|
2009-27 |
May 11, 2009 |
Greece: Summary of New Interpretative Circular Regarding the Transfer Pricing Documentation Rules
|
2009-26 |
May 8, 2009 |
China: Guidance Directs Tax Authorities to Focus on Specific Industries, and Taxpayers with Overseas Investment and Related-Party Transactions
|
2009-25 |
May 7, 2009 |
China: Transfer Pricing Follow-up Measures Enhanced by New Guidance
|
2009-24 |
May 6, 2009 |
United States: New Plans for Enhanced IRS Enforcement of International Transactions
|
2009-23 |
April 28, 2009 |
Thailand: Advance Pricing Agreement Guidelines Are Expected to Be Released in 2009
|
2009-22 |
April 20, 2009 |
Canada: Time Limits for Waivers and Transfer Pricing Reassessments Are Now in Synch
|
2009-21 |
April 15, 2009 |
Determining Taxable Income in Connection with a Cost Sharing Arrangement
|
2009-20 |
April 6, 2009 |
China: Tax Officials Provide Clarification, Insight into Application of Transfer Pricing Regulations
|
2009-19 |
April 2, 2009 |
India: Application of TNMM at Entity Level Is Not Appropriate, and High Degree of Comparability Is Required Under the CUP Method
|
2009-18 |
April 1, 2009 |
India: Appropriate Economic Adjustments May Be Required to Increase Comparability
|
2009-17 |
March 31, 2009 |
IRS Reports Increase in APA Applications Filed for 2008
|
2009-16 |
March 31, 2009 |
United States: IRS Clarifies the “Commencement Date” for Purposes of the Arbitration Process of United States-Belgium Income Tax Treaty
|
2009-15 |
March 25, 2009 |
China: State Administration of Taxation Reminds Local Tax Authorities to Follow New Transfer Pricing Regulations
|
2009-14 |
March 20, 2009 |
Public Comments Released Relating to OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings
Morocco: Tax Provisions in the 2009 Finance Act Include Transfer Pricing Documentation Requirements
|
2009-13 |
March 13, 2009 |
Mexico: New Transfer Pricing Rules Require Disclosure in Statutory Tax Audit Reports, Responses to Questionnaire
|
2009-12 |
March 5, 2009 |
South Africa: What Happens From a Thin Capitalization Perspective When Funding Is Used for a Non-productive Purpose?
|
2009-11 |
March 4, 2009 |
China: Transfer Pricing Reporting Forms Are Incorporated into Tax Authorities' Software
|
2009-10 |
February 24, 2009 |
Singapore: Tax Authority Releases Guidance on Related-Party Loans and Services
|
2009-09 |
February 20, 2009 |
India: Consideration of Subsequent Year Data or Average Profits Not Allowed for Comparability Purposes Under Indian Transfer Pricing Regulations
|
2009-08 |
February 19, 2009 |
India: Payment of Arm’s Length Price to Indian Agent Does Not Extinguish Income Tax Liability of UK Entity in India, Absent Full Consideration of All Activities of the UK Entity and Its Agent in India
|
2009-07 |
February 11, 2009 |
Australia: ATO’s Decision Impact Statement on Roche Products Case
Uruguay: New Rules Focus on Transfer Pricing Enforcement
|
2009-06 |
January 23, 2009 |
Canada Revenue Agency Requires More Data on Cross-Border Transactions
Korea: Q&As on Penalty Relief for Transfer Pricing Adjustments
|
2009-05 |
January 22, 2009 |
Greece: Regulations Implementing the Transfer Pricing Rules
|
2009-04 |
January 12, 2009 |
China: New Transfer Pricing Regulations
Brazil: Guidance Providing Certain Relief From Impact of Transfer Pricing Rules Relating to Exports
|
2009-03 |
January 6, 2009 |
United States: Follow-Up Discussion of Changes Made by 2009 Temporary Regulations to 2005 Proposed Regulations on Cost Sharing Arrangements
|
2009-02 |
January 6, 2009 |
China: Administrative Regulations on Special Tax Adjustments Provide Guidance on Transfer Pricing Issues in China
|
2009-01 |
January 5, 2009 |
India: Transfer Pricing Officer Must Afford Taxpayers with Certain “Natural Law” Rights Before Determining the Arm’s Length Price
United Kingdom: Proposed Changes to Restrict Interest Deductibility Would Operate in Tandem with UK Transfer Pricing Laws
United States: Text of Section 482 Regulations—Methods to Determine Taxable Income in Connection with a Cost Sharing Arrangement
|