Transfer Pricing NEWS The Transfer Pricing Operations (TPO) of the Large Business and International (LB&I) division of IRS released the 26-page Transfer Pricing Audit Roadmap to the public on February 14, 2014. The Transfer Pricing Audit Roadmap (“Roadmap”) provides audit procedures around an approximate 24-month audit timeline. The stated goals of the roadmap are to assist both … Continue reading
Prior to 2012, Ukraine had not been overly concerned about transfer pricing issues. But recently, in the era of fiscal deficits, the Ukrainian government has been more focused on implementing transfer pricing compliance practices in accordance with OECD member countries. Transfer Pricing NEWS On December 4, 2012 the Parliament of Ukraine registered the draft bill … Continue reading
Transfer Pricing NEWS: An exposure draft of legislation was released on November 22, 2012, “Tax Laws Amendment (Cross-Border Transfer Pricing) Bill 2013: Modernisation of transfer pricing rules—proposing changes to Australia’s domestic transfer pricing rules,” to introduce new Australian transfer pricing rules with significant self assessment and documentation requirements. The start date for these new rules … Continue reading
The Queen v. GlaxoSmithKline Inc. – After two decades, still no resolution in Canada Please click on the link for the News on the case, and read below for the Insights. CRA and the OECD The Supreme Court of Canada (SCC) rejected the CRA’s narrow “transaction-by-transaction” approach. What was the CRA thinking? Clearly, the Organisation for … Continue reading
Why is it worth weighing pros and cons of safe harbors*? Because the OECD’s June 6, 2012 draft endorses safe harbors and presents three sample memoranda that countries may use to negotiate bilateral safe harbors. Also, most would say that the IRS has been successful with instituting safe harbors on interest rates for intercompany loans, and … Continue reading
Vietnam’s Ho Chi Minh City tax officials targeting enterprises which reported losses interminably while still expanding business operations December 14, 2012, on the heels of HMRC’s recent interest in Starbucks, Amazon, and Google, Vietnam tax authorities follow suit, investigating Coca-Cola, Adidas, and Metro Cash & Carry for potential causal linkages between transfer pricing and losses in … Continue reading
Did it take almost 2.5 years for the CRA to read the 2010 version of the OECD TP Guidelines? Apparently. CRA released Transfer Pricing Memorandum 14 on October 31, 2012, basically saying they agree with the OECD. Continue reading
Irish Revenue announces transfer pricing compliance review (TPCR) guidance On November 26, 2012, the Irish Revenue issued guidance on how they are proposing to monitor transfer pricing compliance in accordance with Part 35A of the Taxes Consolidation Act 1997. A TPCR is a self-review performed by a company of its compliance with Irish transfer pricing legislation. It appears … Continue reading
Markups on covered services and IRS scrutiny I am interested to know if anyone has experienced IRS scrutiny of services markups in instances where the services are “covered services” under Rev. Proc. 2007-13, but the taxpayer chooses to markup the services using a method (e.g., the cost of services plus method, or the CPM) that … Continue reading
TRANSFER PRICING INSIGHTS 