Transfer Pricing

News & Analysis as of

India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

French Finance Act for 2015 and Amending Finance Act for 2014: Key Tax Measures for Corporations

The French Finance Act for 2015 and Amending Finance Act for 2014 were enacted on December 30, 2014 (the “Acts”). The Acts introduce a new penalty for failure to comply with French transfer pricing requirements, and a...more

MTC Puts Designs on Increasing State Transfer Pricing Revenues

This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length...more

A swift look at the OECD discussion drafts on BEPS plus one chart setting out timelines

During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to financials, the OECD released several BEPS (Base Erosion and Profit Shifting) discussion drafts,...more

McKesson: Taxpayer Files Supplementary Factum

As expected, the taxpayer has filed a Supplementary Memorandum of Fact and Law in its transfer pricing appeal in the Federal Court of Appeal. Earlier, the Federal Court of Appeal allowed the taxpayer’s motion to add a new...more

Multistate Tax Commission Gauges State Interest in Funding Transfer Pricing Expertise and Expands Audit Program

At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer...more

McKesson: Additional Submissions on Motion

In the most recent developments in the McKesson transfer pricing case, the Respondent has filed its Written Representations in response to the Appellant’s motion to raise new issues on appeal, and the Appellant has filed a...more

Beleaguered D.C. Taxpayers Achieve Another Success in Ongoing Challenges to the Methodology Used in the District’s Transfer...

On Friday, November 14, 2014, an administrative law judge (ALJ) issued three identical orders granting the taxpayer’s motion for summary judgment in Hess v. OTR, Shell v. OTR and ExxonMobil v. OTR. In these orders, the ALJ...more

Upcoming Nationwide Transfer Pricing Investigation Against Outbound Service Fee And Royalty Payments

On 29 July 2014, the China State Administration of Taxation (SAT) released an internal notice to the China tax authorities at the provincial levels, in the name of "Notice on Antiavoidance Investigation against Large Amount...more

Multistate Taxpayers Take Note! Recap of the First Day of the MTC Pricing Summit

On October 6, 2014, the Multistate Tax Commission (MTC) held the first day of a two-day meeting intended to educate state revenue authorities on corporate income tax issues surrounding intercompany transactions, and further...more

Legal Alert: MTC Meets With Economic Firms to Continue Its Transfer Pricing Effort

On October 6, the Multistate Tax Commission Arm’s-Length Adjustment Service Advisory Group (the “Group”) met in Atlanta, Georgia, to continue its foray into transfer pricing audits. The Group first met in June and has met...more

Judicial Review Application Preserved in Transfer Pricing Penalty Case

A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be – even one a taxpayer believed had been resolved! It also represents a rare situation in which the taxpayer’s...more

McKesson: Trial Judge Recuses Self From Two Remaining Issues in Transfer Pricing Case

In McKesson v. The Queen (2014 TCC 266), Justice Patrick Boyle recused himself from the two remaining issues with which he was seized in the transfer pricing case – costs and the content of the court’s public file (i.e., the...more

Connecticut Hires Chainbridge Software LLC for Transfer Pricing Training

On July 15, 2014, the Connecticut Department of Revenue Services awarded Chainbridge Software LLC a contract worth $50,000 for on-site and remotely supported training for transfer pricing audits. Chainbridge is infamous for...more

Cahiers de droit fiscal international: Ukraine Cross-border outsourcing - issues, strategies and solutions

Summary and conclusions - Ukraine is experiencing the fast development of outsourcing industry due primarily to IT outsourcing. This is supported by tax incentives introduced for the IT sector. Ukrainian tax...more

Revised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation

CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements in substantially more...more

Legal Alert: MTC Speaks with Potential Transfer Pricing Vendors

On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment...more

Marzen: Tax Court Upholds Transfer Pricing Adjustments

The decision of the Tax Court of Canada in Marzen Artistic Aluminum Ltd. v. The Queen (2014 TCC 194) is the latest addition to a growing body of Canadian judgments on the application of the transfer pricing rules in section...more

Alabama Joins Transfer Pricing Advisory Group to Develop New Service for the Multistate Tax Commission

Alabama has joined the District of Columbia, Florida, Georgia, Hawaii, Iowa, Kentucky, New Jersey, and North Carolina as members of the Arm’s Length Adjustment Services (ALAS) Advisory Group, a new project by the Multistate...more

MTC Launches Transfer Pricing Effort

On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more

Luxembourg: recent developments in transfer pricing and tax ruling practice

The Luxembourg tax authorities are currently carrying out transfer pricing audits, particularly for financing companies. When the transfer prices are not substantiated through proper documentation, the Luxembourg tax...more

Information Letter: Transfer Pricing in Russia: What is the Likelihood of an Audit?

On 20 November 2013 for the first time Russian taxpayers should have filed with controlling authorities notifications on controlled transactions (“Notifications”) in accordance with the new transfer pricing rules. According...more

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more

MTC State Transfer Pricing Program Looms on the Horizon

Transfer pricing is usually considered an international affair, but state governments, like there larger national brethren, have increasingly, and painfully, come to realize that inter-state transfer pricing has become a...more

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