Transfer Pricing News
Panel Says Nortel Underfunded U.K. Subsidiary’s Pension FundA June 25 determination by a panel of the U.K. Pensions Regulator states that 25 companies in the Nortel group must provide up to £2.1 billion (US$3.3 billion) to a U.K. subsidiary’s pension fund, saying the group’s improper transfer pricing regime was designed to create a shortfall in the fund. [U.K. Pension Regulator's Financial Support... [Read more of this article]
A Look at Expert Witness Reports in Australia’s SNF Litigation
Expert witness reports filed on behalf of the Australian Taxation Office in the recent case of SNF (Australia) Pty. Ltd. v. Comr. made a strong case for the Federal Court to reject SNF (Australia)’s comparable uncontrolled price method and to instead adopt the ATO’s proposed transactional net margin method. However, the court chose to uphold... [Read more of this article]
Former Brazilian Tax Official Addresses Country’s Unique Methods
Elen Peixoto Orsini, a former auditor with the Brazilian Federal Revenue Service for over two decades and head of the transfer pricing inspection division of the Special Division for International Affairs from 2000-01, shared her views on a broad spectrum of Brazilian transfer pricing issues in a Aug. 9 interview. In written responses to questions... [Read more of this article]
APA Move Could Mean More Efficiency, Less Independence, Practitioners Say
With the Advance Pricing Agreement Program’s inventory at an all-time high and a four- to six-month wait for work to begin on cases, practitioners seem less opposed to a possible combining of the Internal Revenue Service’s Competent Authority and APA staff than they were when the issue was raised in both 1993 and 2000. Some pointed out... [Read more of this article]
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Transfer Pricing Events and Training
8 October – Advanced Transfer Pricing Workshop: Tangible Goods/Intangible Property/ServicesAdvanced transfer pricing workshop: Tangible goods/intangible property/services in London How you will benefit:Develop an awareness of the complexities that arise in planning a project Understand how to develop a feel for a viable strategy Learn ways of dealing with various transactions and how to find data to set the priceAgendaPlanning the... [Read more about this event]
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