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]

Japan to Require Submission Of All MAP Cases Directly to NTA

TOKYO — Japan has amended its submission process for mutual agreement procedure cases to require all requests for competent authority relief to be filed directly with the National Tax Administration, the NTA said in a statement posted to its website July 22. Under the change, effective Oct. 1, taxpayers that currently submit MAP requests with the... [Read more of this article]

Implementing your transfer pricing policy

Deborah Green and Sarah Norton, KPMG, London So you have done the hard bit; you have developed your multinational’s transfer pricing policy, all the documentation is in place; you can sit back and relax, yes? No. Businesses constantly change; therefore, transfer pricing policies need to be maintained to make sure they keep pace with the changing... [Read more of this article]

Russia: Regulations clear lower house of Parliament

Vladimir Starkov, NERA Economic Consulting, Chicago After a long deliberation period that started in late 2009, the lower house of the Russian parliament (State Duma) approved the final draft of the law containing the new Russian transfer pricing regulations on July 8. The specified effective date of the law is January 1, 2012, provided that the draft... [Read more of this article]

WCO: Converging transfer pricing and customs valuation rules

Philippe Orban and Dirk Van Stappen, KPMG, Belgium Once called “a landmark” by World Customs Organisation (WCO) officials, what is the meaning of Commentary 23.1 and what are the consequences of the publication of Commentary 23.1? The debate concerning the different rules between transfer pricing and customs valuation is not new. Frustrated by... [Read more of this article]

Brazil: Thin cap rules clarified

Nearly 11 months after enactment, Brazil’s thin capitalisation rules have been clarified in Normative Ruling No. 1,154/2011 (NR 1,154), published in the Official Gazette on May 13, 2011. The original thin capitalisation rules were introduced by Provisional Measure 472/09 and converted into Law 12,249/10 in June 2010. The new NR provides guidance... [Read more of this article]

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