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Latest News
Global governments are getting hungrier » Virtually all transactions that cross international borders have tax implications - and as more and more clients engage in business around the world, international tax issues are becoming increasingly important to practitioners of every size.Read more >>
The arm’s-length standard in US and UK transfer pricing rules » In transactions between related entities across jurisdictions, transfer pricing rules act to allocate profits and losses in a fair and economically justifiable manner to best reflect revenues and costs of each party to the transaction. Bruce Clements and Alan Clements of Clements Law Office discuss ...
IPR Plaza launches website » IPR Plaza is a multidisciplinary portal that provides free-of-charge qualitative and quantitative information on intangibles and is empowered by different leading IP advisory firms and delivers up-to-date guidance on intangibles  from IP Law,  Accounting, IP Management, Antitrust, and Tax/...
Foundation of Brazilian transfer pricing rules changed » Brazil has introduced measures that affect the country's fundamental transfer pricing regulations. Executive Measure (EM) 563, published on April 4 2012, introduced, among other provisions, important changes to Law 9430/96 (Law 9430), which is the main rule on transfer pricing matters in Brazil. The...
Vietnam Tax Authorities strengthen transfer pricing enforcement » Hong Kong - Vietnam’s tax authorities have further strengthened their focus on enterprises suspected of transfer pricing abuses, with attention paid particularly to those with reported consecutive losses/low profitability for financial years 2008 to 2010. For taxpayers in that position, the time has...
Australia | ATO Risk Assessments » The Australian Taxation Office (“ATO”) has announced that it is currently writing to large businesses about the ATO’s assessment of their level of tax risk and that it is looking to meet with the senior executives of those taxpayers to explain their assessment. These tax risk assessments address iss...
El Salvador launches transfer pricing regulations » El Salvador has passed transfer pricing regulations with immediate compliance requirements. Taxpayers are expected to file documentation by May 31 in-line with the Dictamen Fiscal.Read more >>
How to prepare for a Transfer Pricing Audit » The chances of a multinational being confronted with a transfer pricing audit have substantially increased over the last few years. Due to the intense focus on transfer pricing by almost all tax authorities around the globe, together with growing focus on international exchange of information, it se...
Dutch authorities: How to improve your relationship » Jasper Arendse, senior policy adviser at the Dutch Ministry of Finance explains how taxpayers can improve their relationship and communication with officials when confronting transfer pricing issues. Our International Tax Policy and Legislation Directorate has a lot of mutual agreement procedures (M...
India rules that officers cannot disallow royalty based on incurred losses » The Delhi High Court has ruled that the transfer pricing officer (TPO) cannot disallow royalties just because the company paying them is incurring losses. The ruling stated that, among other things, the authorities cannot use the financial health of a taxpayer as an excuse to disallow an expense.Rea...
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