Transfer pricing in France in 2011

Julien Monsenego and Rui Cabrita, Olswang France LLP, Paris2011 saw an increase in transfer pricing cases before the Conseil d’Etat l. DocumentationOn January 4, 2011, the French tax authorities published guidelines on new requirements that had been introduced relating to specific transfer pricing documentation (the “Guidelines”). The... [Read more of this article]

Indonesia: New guidance on transfer pricing rules

Firdaus 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]

Documentation in the Netherlands

Michiel van den Berg, Grant Thornton Accountants en Adviseurs B.V., Gouda On March 30, 2001 The Netherlands issued a Transfer Pricing Decree which provided policy with respect to transfer pricing: transfer prices, the application of the arm’s length principle and the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations... [Read more of this article]

Mexico’s SAT Appeals First-Ever Ruling For Taxpayer in Transfer Pricing Trial

MEXICO CITY — Mexico’s tax authority has appealed a ruling by a federal tax court that for the first time ever decided in favor of a company in a transfer pricing trial, according to Ernst & Young experts who represented the company. Jorge Castellon, Mexico’s national transfer pricing director at E&Y, said the government’s... [Read more of this article]

CRA’s Latest MAP Report Shows Output Exceeding Input for ‘Negotiable’ Cases

While the Canada Revenue Agency’s July 29 report on mutual agreement procedure cases showed the Agency resolving more “negotiable” cases than it took on for the first time in years, it also revealed those cases to be a small percentage of overall MAP disputes. The CRA’s latest MAP report shows that it accepted, for the 2010-11 fiscal... [Read more of this article]

Australia: Disclosure of reportable tax positions

Lyndon James, Zara Ritchie and Sarah Stevens, PwC, Sydney and MelbourneThe Australian Taxation Office (ATO) has released a draft Reportable Tax Position (RTP) Schedule, which will require some large business taxpayers to disclose information about reportable tax positions (i.e. uncertain or contestable positions) in an attachment to their annual... [Read more of this article]

Pending China-U.K.Treaty Adopts Services PE Concept

The pending China-U.K. income tax treaty has adopted the services permanent establishment concept and also updates the PE definition of construction project. The treaty, signed in London June 27, will enter into force when both countries have completed their ratification procedures. Revised Article 5 of the pending treaty states that the furnishing... [Read more of this article]

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