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Latest News
Vietnam Tax Authorities strengthen transfer pricing enforcement » Hong Kong - Vietnam’s tax authorities have further strengthened their focus on enterprises suspected of transfer pricing abuses, with attention paid particularly to those with reported consecutive losses/low profitability for financial years 2008 to 2010. For taxpayers in that position, the time has...
Australia | ATO Risk Assessments » The Australian Taxation Office (“ATO”) has announced that it is currently writing to large businesses about the ATO’s assessment of their level of tax risk and that it is looking to meet with the senior executives of those taxpayers to explain their assessment. These tax risk assessments address iss...
India | Budget amendments to TP regulations » The Finance Minister presented the Finance Bill 2012 (Finance Bill) in the Parliament on March 16, 2012 proposing significant amendments in the transfer pricing (TP) regulations. In recent times, taxpayers in India have been confronted with large scale litigation in TP and conflicting judicial r...
Foundation of Brazilian transfer pricing rules changed » Brazil has introduced measures that affect the country's fundamental transfer pricing regulations. Executive Measure (EM) 563, published on April 4 2012, introduced, among other provisions, important changes to Law 9430/96 (Law 9430), which is the main rule on transfer pricing matters in Brazil. The...
The Australian government has released an exposure draft of proposed amendments to the transfer pricing regime » The draft follows an initial announcement and consultation in November 2011 and confirms that the transfer pricing articles contained in Australia's tax treaties are able to be applied and operate independently of Australia's unilateral transfer pricing rules.Read more >>
El Salvador launches transfer pricing regulations » El Salvador has passed transfer pricing regulations with immediate compliance requirements. Taxpayers are expected to file documentation by May 31 in-line with the Dictamen Fiscal.Read more >>
Ireland Set For New Transfer Pricing Rules » Speaking at PricewaterhouseCoopers’s ‘Supporting Growth - Protecting Wealth’ conference, Siobhan Baldwin, Tax Director in PwC’s Private Company Services arm, warned of changes to Irish transfer pricing rules that will affect arrangements made after July 1, 2010. She told participants that in the mos...
Ghana and Cameroon tighten transfer pricing » African nations are strengthening their tax systems and transfer pricing has become a new focus in the region. Ghana is the most recent country to implement transfer pricing legislation, with assistance from the German development agency, GIZ. Read more >>
The arm’s-length standard in US and UK transfer pricing rules » In transactions between related entities across jurisdictions, transfer pricing rules act to allocate profits and losses in a fair and economically justifiable manner to best reflect revenues and costs of each party to the transaction. Bruce Clements and Alan Clements of Clements Law Office discuss ...
Global governments are getting hungrier » Virtually all transactions that cross international borders have tax implications - and as more and more clients engage in business around the world, international tax issues are becoming increasingly important to practitioners of every size.Read more >>
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