Transfer Pricing

Why country by country reporting is not compatible with transfer pricing realities

Mon, 20 Feb 2012 00:00:00 GMT

An estimated $110 billion disappeared because of transfer mispricing on the import of crude oil in the EU and US between 2000 and 2010, a recent report from Publish What You Pay (PWYP) Norway said.

Tax transparency in the spotlight like never before

Fri, 17 Feb 2012 00:00:00 GMT

Companies around the world are beginning to understand the importance of transparency about their tax affairs and the reputational benefits of eschewing aggressive tax planning. They will have the opportunity to debate these crucial issues with administrators, activists and practitioners at International Tax Review's first Tax & Transparency Forum on May 2.

European Tax Awards 2012: Entries close on February 14

Mon, 13 Feb 2012 00:00:00 GMT

Firms with offices throughout Europe and South Africa have until tomorrow to enter for International Tax Review's European Tax Awards

ANALYSIS: How GSK’s Canada SC hearing unfolded

Tue, 17 Jan 2012 00:00:00 GMT

The Supreme Court of Canada met last week to hear the Canadian Revenue Authority’s (CRA) appeal and GlaxoSmithKline’s (GSK) response in a case to decide whether GSK paid too much for active pharmaceutical ingredients (API) from a Swiss associated enterprise.

How tax could replace aid for developing countries

Mon, 16 Jan 2012 00:00:00 GMT

Speaking to International Tax Review, Pascal Saint-Amans, the incoming head of tax policy and administration at the OECD, highlighted the goal of replacing aid with tax collection. But what will it mean for taxpayers?

What Republicans want in new US tax system

Tue, 01 Nov 2011 00:00:00 GMT

US corporations are fully behind the principles in a discussion draft from members of the House Ways and Means Committee on moving to a territorial tax system, if early reaction is a good guide.

Euromoney Legal Media Group Asia Women in Business Law Awards

Mon, 31 Oct 2011 00:00:00 GMT

The shortlists for the inaugural Euromoney Legal Media Group Asia Women in Business Law Awards have been announced.

EXCLUSIVE: Pascal Saint-Amans defines his role as new OECD head of tax policy and administration

Tue, 25 Oct 2011 00:00:00 GMT

When Jeffrey Owens announced his retirement as head of tax policy and administration at the OECD, the race was on to replace one of the most important figures in global tax affairs. Pascal Saint-Amans is that man and, in an exclusive interview, he discusses his priorities on transparency, transfer pricing and tax avoidance before taking up the position in February.

FREE: Google’s valuation of intangibles under audit

Thu, 20 Oct 2011 00:00:00 GMT

Google is under audit in the US following reports it uses transfer pricing to reduce its overseas effective tax rate down to just 2.4%.

Transfer pricing grabs taxpayers' attention

Tue, 27 Sep 2011 00:00:00 GMT

Delegates at International Tax Review's Global Transfer Pricing Forum in London last week had many questions and concerns about transfer pricing that ranged from intangibles to financial transactions.

New Zealand Revenue confuses with approach to related-party transaction

Thu, 22 Sep 2011 00:00:00 GMT

A court case on debt finance is creating waves because it seems the Inland Revenue Department (IRD) is contradicting its own guidelines.

The double taxation risks in cross-border restructuring

Mon, 19 Sep 2011 00:00:00 GMT

The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday.

The Global Transfer Pricing Forum starts tomorrow

Mon, 19 Sep 2011 00:00:00 GMT

International Tax Review's 11th annual Global Transfer Pricing Forum opens tomorrow at 9am.

PwC US adds transfer pricing and tax controversy principal

Tue, 23 Aug 2011 00:00:00 GMT

Gregory Barton has joined the firm and will be based in the Chicago office. He will operate in both the transfer pricing and tax controversy and dispute resolution practices.

Indian taxpayers face challenging future

Tue, 26 Jul 2011 00:00:00 GMT

Next year will herald a widescale period of change for tax in India. It will force tax directors from domestic and international companies to completely reconsider their strategies and to seek efficiencies at all levels of their company's tax affairs.

It is transfer pricing but not as we know it

Fri, 01 Jul 2011 00:00:00 GMT

The CCCTB concept of relies on formulary apportionment, doing away with the arm’s-length principle (ALP). While many people welcome the opportunity to debate the future of tax compliance, others feel a switch to formulary apportionment will create just as many problems as the ALP. Sophie Ashley talks to the CCCTB’s critics and supporters about its impact on transfer pricing.

France goes after local level profits and local expenses

Fri, 01 Jul 2011 00:00:00 GMT

The French requirements for transfer pricing documentation have to a certain extent secured the position of French subsidiaries. Multinational companies now face confusion from French tax authorities between the shareholders and management decisions. Financial consequences are huge. Isabelle Vendeville of Redlink investigates.

OECD analyses transfer pricing simplification measures

Wed, 15 Jun 2011 00:00:00 GMT

The OECD has released a multi-country analysis of existing transfer pricing simplification measures.

Pakistan mulls documentation requirements

Wed, 01 Jun 2011 00:00:00 GMT

Asia directors unveil long list of concerns

Wed, 01 Jun 2011 00:00:00 GMT

After last month’s Asia Tax Executives’ Forum in Singapore, International Tax Review investigates the real issues Asian tax directors face on a daily basis as they experience greater scrutiny from authorities while at the same time finding their work being placed higher on their board’s agenda.

Court of Appeal rules that a commissionaire company constitutes an agency PE of its principal company

Wed, 01 Jun 2011 00:00:00 GMT

Tips to survive your Vietnamese transfer pricing audit

Wed, 01 Jun 2011 00:00:00 GMT

Nominees announced for Women in Business Law Awards

Thu, 26 May 2011 00:00:00 GMT

The leading female practitioners in Europe for tax, transfer pricing, tax dispute resolution and trusts and estates advice will be honoured at the first European Women in Business Law awards in London on June 29.

Asia tells tax transparency story

Wed, 11 May 2011 00:00:00 GMT

The age of tax scrutiny has arrived, a practitioner told International Tax Review's Asia Tax Executives ' Forum today.

European Awards nominees published

Thu, 07 Apr 2011 00:00:00 GMT

The shortlists for International Tax Review's European Tax Awards have been announced.

European Commission proposes CCCTB

Wed, 16 Mar 2011 00:00:00 GMT

The European Commission today unveiled its proposal for a common consolidated tax base (CCCTB) system for calculating the tax base of businesses operating in the EU.

CRA pressed to sharpen auditing process

Tue, 01 Mar 2011 00:00:00 GMT

Countries around the world are improving their auditing efforts to compensate for overwhelming debt burdens and Canada is no exception.

European Commission proposes CCCTB

Tue, 01 Mar 2011 00:00:00 GMT

The European Commission today unveiled its proposal for a common consolidated tax base (CCCTB) system for calculating the tax base of businesses operating in the EU.

European Commission proposes CCCTB

Tue, 01 Mar 2011 00:00:00 GMT

The European Commission today unveiled its proposal for a common consolidated tax base (CCCTB) system for calculating the tax base of businesses operating in the EU.

Budget proposals could make India the “strictest TP regime in the world”

Mon, 28 Feb 2011 00:00:00 GMT

India’s budget, announced today, could make India one of the strictest transfer pricing regimes in the world, according to advisers.