Transfer Pricing

Legal Alert: MTC Explores Transfer Pricing Audits, Shelves Pass-Through Entity Project

by Sutherland Asbill & Brennan LLP on 5/13/2013

On Thursday, May 9, the Multistate Tax Commission (MTC) hosted an Executive Committee (Committee) meeting in Washington, D.C. The Committee discussed many items ranging from election of new officers to Committee updates to...more

Carrying on Business in Canada

by Heenan Blaikie LLP on 5/3/2013

In This Publication: - Preface - General Information - Immigration - Investment Factors - Intellectual Property - Principal Forms of Business Entities - Taxation -...more

Taxpayer Challenges Validity of IRS Transfer Pricing Regulation

by Steven Hannes | McDermott Will & Emery on 4/19/2013

In a petition recently filed in the U.S. Tax Court, a taxpayer has challenged the Internal Revenue Service (IRS) regulation that provides that the IRS can reallocate income between affiliates even when foreign law prohibits...more

The Italian Advance Pricing Agreements

by Mario Martinelli | McDermott Will & Emery on 4/3/2013

The International Ruling Office (the Office) of the Agenzia delle Entrate (the Italian Revenue Agency) has finally released the second issue of the Bulletin, almost three years after the release of the first issue. ...more

India at the Crossroads

by A. Tracy Gomes | McDermott Will & Emery on 3/26/2013

India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more

Update from the MTC's Winter Committee Meetings: Transfer Pricing and Financial Institution Apportionment

by Sutherland Asbill & Brennan LLP on 3/6/2013

During the Multistate Tax Commission’s (MTC ) Winter Committee Meetings in St. Louis on March 5, 2013, the Income and Franchise Tax Uniformity Subcommittee (I/F Subcommittee) declined to move forward with a project that would...more

Russian Transfer Pricing Law

by A. Tracy Gomes, Cym H. Lowell | McDermott Will & Emery on 2/26/2013

Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more

International Tax & Transfer Pricing Strategies in the Crosshairs

by Claire M.C. Kennedy | Bennett Jones LLP on 2/22/2013

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

Government Releases New Transfer Pricing Measures to Attack Multinationals

by Tamara Cardan, Philip Diviny | K&L Gates LLP on 2/21/2013

On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied. The legislation will come...more

Marketing Intangibles in International Transfer Pricing

by Claire M.C. Kennedy | Bennett Jones LLP on 1/29/2013

An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. In that case,...more

Multilateral Advance Pricing Agreements

by Cym H. Lowell | McDermott Will & Emery on 1/16/2013

As transfer pricing examination and controversy continue to grow, it’s becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically...more

Worthless Stock Deductions: Valuation, Transfer Pricing and Technical Considerations

by A. Tracy Gomes, Cym H. Lowell | McDermott Will & Emery on 12/7/2012

When a multinational enterprise (MNE) has affiliates that have become insolvent, the overall tax planning objective frequently is to secure a U.S. tax deduction (often ordinary) for worthless stock or debt. The essential...more

Supreme Court of Canada Establishes Important Principles in Transfer Pricing

by Claire M.C. Kennedy, Martin P.J. Kratz Q.C., Darrel H. Pearson | Bennett Jones LLP on 12/3/2012

The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc.,1 (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation...more

Supply Chain Efficiency: Valuation and Transfer Pricing Considerations

by McDermott Will & Emery on 8/2/2012

Deriving maximum cost efficiency from the supply chain is a critical operational issue for multinational enterprises (MNEs) in certain regions. As taxation is typically one of a group’s largest costs, supply chain...more

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