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- Category: Transfer Pricing Events and Training
- Category: Transfer Pricing News
- 2010 revision of the OECD guidelines: Is my business restructuring going to lead to an indemnification payment or exit charge?
- 2010 revision to the OECD guidelines
- A Look at Expert Witness Reports in Australia's SNF Litigation
- ABA Panelists Explore Cost Sharing After Veritas, Xilinx Rulings
- ABA Panelists to Consider Guarantee Pricing In Light of Limited Guidance from IRS, OECD
- Administrative Court Finds Semp Toshiba Must Follow Pricing Formula in Norm 243
- Advance Pricing Agreements in Germany
- Advance Pricing Agreements: A UK Perspective
- Algeria: documentation rules in 2010 “Additional” Finance Act
- Amgen Tax Official Describes Importance Of Fully Describing Company, Transfer Pricing at Audit
- An Econometric Adjustment for Risk
- ANALYSIS: Australia's Federal Court Considers Distributor SNF's Case
- ANALYSIS: Rebalancing the Functional Analysis: Functions, Assets, and Risks
- ANALYSIS: Should You Use Chinese Private Comparables?
- ANALYSIS: The Demise of the Arm's-Length Principle? Or How to Make the Arm's-Length Principle Workable
- ANALYSIS: Transfer Pricing and Customs Nirvana: Is It Possible?
- ANALYSIS: U.S. International Trade Commission Issues Report on Importers' Use of Customs First Sale Rule
- APA Move Could Mean More Efficiency, Less Independence, Practitioners Say
- APA Officials Discuss New Procedures Including Scrutiny of Unilateral Submissions
- Argentina - management services
- As Two-Year Deadline Looms for U.S.-Canada Arbitration, Practitioners Discuss APA Coverage, Other Unresolved Issues
- AstraZeneca Pays IRS $1.1 Billion To Settle Transfer Pricing Issues
- ATO May Apply Arm's-Length Rate To Interest Despite Thin Cap Safe Harbor
- Australia Contemplates Using OECD Methods To Value Coal and Iron Under New Mining Tax
- Australia Issues Guidance Reiterating ATO View on Thin Cap Safe Harbor
- Australia: Disclosure of reportable tax positions
- Brazil
- Brazil Adopts Thin Capitalization Rules; Loans to Tax Havens Face More Restrictions
- Brazil Provision Introduces New Method, Enacts Other Transfer Pricing Rule Changes
- Brazil: Final Thin Capitalisation Rules Introduced
- Brazil: Thin cap rules clarified
- Brazilian Ministry of Finance Has Yet To Allow Requests to Change Fixed Margins
- Canada, United States Canada Likely to Reciprocate U.S. Policy On APA Rollbacks, Post-Return Adjustments
- Canada-US: arbitration under treaty arrives
- Canada: Audit exposures and remedies
- Canadian Appeals, Competent Authority Work to Clarify Interaction, O'Riordan Says
- Canadian use of APAs as a planning tool in the current economic climate
- Cases, Recent Policy Define Disclosure Landscape in Canada
- China Completes Second Shanghai APA; Taxpayer Operates in Free Trade Zone
- China Expands Thin Cap Rules To Include Loans Made by Individuals
- China Makes Adjustments of $2.35 Billion, Recovering Tax of $308 Million in 2009
- China: first bilateral APA for Shanghai
- China: increased transfer pricing risks for auto-makers
- China: nationwide requests for documentation
- China: Notice 698 – the death of offshore holding structures?
- Chinese Officials Cite Staffing Hurdles, Lack of Cooperation from Other Jurisdictions
- Comparable Data Searches, TNMM Use Examined in 27-Country Survey
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