Archive: transfer pricing
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Spain establishes National Office for International Taxation [TAX ALERT]
May 23, 2013. Tags: advanced pricing agreement, international tax, Spain, tax audit, transfer pricing
In April 2013, the Spanish Government established the National Office for International Taxation (Oficina Nacional de Fiscalidad International “ONFI”) an élite force that will focus …
Italy releases APA program Bulletin – second edition [TAX ALERT]
May 21, 2013. Tags: APA, Italy, transfer pricing
On 20 March 2013, Italy released the second Bulletin of its APA (Advanced Pricing Agreement) program. The most interesting development is the significant increase in pre-filing …
Argentina modifies transfer pricing regulations [TAX ALERT]
May 16, 2013. Tags: Argentina, transfer pricing
On 10 April 2013, the Argentine Federal Tax Authorities (Administración Federal de Ingresos Públicos or AFIP) published General Resolution N° 3,476 in the Official Bulletin …
US IRS issues fourteenth Annual APA report for 2012 [TAX ALERT]
May 15, 2013. Tags: advanced pricing agreement, transfer pricing, United States
The US IRS issued the fourteenth annual Advance Pricing Agreement (APA) report (the Report) on 25 March 2013, in Announcement 2013-17. The Report provides an updated …
India: decision that DRP is empowered to enhance transfer pricing adjustments
May 13, 2013. Tags: income tax, India, transfer pricing
The Income Tax Appellate Tribunal (ITAT) issued its decision, on 19 April 2013, in the case of Hamon Shriram Cottrell Pvt.Ltd vs. ITO (ITA No. …
Russia adopts deferral of key transfer pricing deadlines and the exclusion of certain loans for transfer pricing control [TAX ALERT]
May 10, 2013. Tags: Russia, transfer pricing
The planned changes to Russia’s new transfer pricing rules contained in Law No. 79859-6 have been adopted by the State Duma on 22 March 2013. The …
OECD: Global Forum on Transfer Pricing releases Draft Handbook on Transfer Pricing Risk Assessment
May 6, 2013. Tags: OECD, tax risk, transfer pricing
On 30 April 2013, the OECD published a Draft Handbook on Transfer Pricing Risk Assessment, produced by the Steering Committee of the OECD Global Forum …
US: IRS LB&I issues Competent Authority Statistics [TAX ALERT]
April 30, 2013. Tags: APA, IRS, tax policy, transfer pricing, United States
On 14 March 2013, the Internal Revenue Service (IRS) released the Large Business & International (LB&I) Division Competent Authority Statistics for the fiscal year ended …
India: clarification on computation of arm’s length price
April 30, 2013. Tags: income tax, India, transfer pricing
On 15 April 2013, the Government issued clarifications via Notification No. 30/2013 on the computation of the arm’s length price (ALP) for different categories of …
US: Transfer pricing – safe harbors on the horizon? [TAX ALERT]
April 29, 2013. Tags: transfer pricing, United States
The potential for multinational companies to use transfer pricing to shift income to low-tax jurisdictions has always been a major concern of the United States …
French TP documentation regulation formalizes enforcement efforts [TAX ALERT]
April 25, 2013. Tags: France, tax administration, transfer pricing
The French transfer pricing (TP) regulatory environment has undergone very significant changes over the past three years. The most apparent change is the introduction of the …
Mumbai Tribunal rules on transfer pricing aspects of intra-group software development services [TAX ALERT]
April 18, 2013. Tags: income tax, India, transfer pricing
This Tax Alert summarizes a recent ruling of the Mumbai Income-Tax Appellate Tribunal (Tribunal) in the case of M/s. Capgemini India Private Limited (Taxpayer) on …
United States: IRS releases annual transfer pricing APA report for 2012
April 4, 2013. Tags: IRS, transfer pricing, United States of America
The US Internal Revenue Service (IRS) released its annual report for 2012 on advance pricing agreements (APAs) and the advance pricing and mutual agreement (APMA) …
Russia: new transfer pricing deadlines proposed
March 20, 2013. Tags: Russia, transfer pricing
Draft Law No. 79859-6, sent for the second reading in the State Duma (the lower chamber of the Parliament), provides for new deadlines for taxpayers …
Korea: arm’s length calculation for intercompany guaranty transactions clarified
March 19, 2013. Tags: Korea, tax law, transfer pricing
In response to a growing number of disputes involving companies receiving guarantee fees from their foreign subsidiaries, the Ministry of Strategy and Finance (MOSF) has …
French Appellate Court rules conversion from full-fledged distributor to commissionaire a nontaxable event [TAX ALERT]
March 15, 2013. Tags: France, transfer pricing
The tax implications of a conversion from one business model to another, requires careful examination by taxpayers before being implemented. The French Tax Authorities (FTA) are …
The impact of Australia’s new transfer pricing rules [TAX ALERT]
March 13, 2013. Tags: Australia, transfer pricing
The Australian Government has re-engineered the transfer pricing law for international business transactions and adjusted the general antiavoidance rule (Part IVA, Australia’s GAAR). The Tax Laws …
Russia: commodities subject to transfer pricing control rules
March 11, 2013. Tags: oil and gas, Russia, tax code, transfer pricing
As a general rule, the Tax Code provides that transactions concluded with related parties are subject to transfer pricing control. In addition to this, however, in …
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