Transfer Pricing News
Indonesia: New guidance on transfer pricing rulesFirdaus Asikin and Connie Chu, Deloitte Indonesia, Jakarta Indonesia’s Tax Office (ITO) issued a new regulation (PER-32) on November 11, 2011 that amends and clarifies the transfer pricing rules and brings them more in line with the OECD guidelines. The new rules came into effect on the date of issuance. PER-32 aims to broaden the scope of the... [Read more of this article]
The McKesson case: Key transfer pricing principles in the context of debt factoring
Dr Danny Beeton and Dr Rupert Macey-Dare, Freshfields Bruckhaus Deringer, London Danny Beeton is Head of Transfer Pricing Economics; Rupert Macey-Dare is a member of the Dispute Resolution and Transfer Pricing practiceThe trial of McKesson Canada Corporation v. The Queen commenced in the Tax Court of Canada in Toronto on October 17, 2011 and is expected... [Read more of this article]
Documentation in Finland
Santeri Kããriãinen and Tanja Lappalainen, Revico Grant Thornton Oy, HelsinkiTransfer pricing refers to the pricing of transactions between associated companies, that is, in general it applies to transactions between group companies. The international basis for transfer pricing is the arm’s length principle. According to the principle, the... [Read more of this article]
Latest Roundup of Indian Cases Shows Courts Tackling Marketing Intangibles, Loan Guarantees
A recent survey of Indian transfer pricing cases reveals that while the country’s international tax appellate tribunals are beginning to touch on substantive transfer pricing issues, such as the treatment of marketing intangibles and loan guarantees, many of the ITAT opinions continue to focus on procedural issues and fail to create substantive... [Read more of this article]
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Transfer Pricing Events and Training
5th International Taxation Conference 20111st-2nd December – Central University of Finance and Economics, Beijing, ChinaA valuable opportunity for MNCs and tax practitioners to interact with revenue authorities. With representatives from the IRS, high-level officials from SAT China, the Ministry of Finance of India and experts from OECD, the 5th International Taxation Conference on... [Read more about this event]
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