.jpg) Arm's Length Standard is a bi-monthly transfer pricing newsletter designed to keep senior tax executives updated on transfer pricing developments around the world, featuring news and analyses from the transfer pricing professionals in Deloitte member firms. Subscribe to receive Arm's Length Standard directly via email (e-newsletters are managed out of the United States). August/September 2008 - Technical explanation of Canada-U.S. protocol provides guidance on attribution of profits to permanent establishments and arbitration
- Singapore introduces transfer pricing reviews
- Israeli tax authorities issue circular defining TP documentation requirements
- Portugal issues APA guidelines
- U.K. tax authorities publish new transfer pricing guidance
- Taiwan approves “markup on total costs” as profit level indicator for transfer pricing
- IRS release of new cost sharing regs imminent
- Germany approves regulations on the relocation of functions
- ATO releases annual compliance program statement for 2008-09; transfer pricing continues to be area of concern
- New Brazilian law broadens transfer pricing concept of “tax haven”
- Australian high court rules ATO not required to state reasons behind transfer pricing adjustments
- Hungarian transfer pricing survey shows many taxpayers unprepared for audits
- India tribunal’s decision provides guidance on comparables
June/July 2008 - Canadian court decision causes indigestion for Glaxo
- Italian court hands down controversial decision on intercompany service charges
- Turkey extends deadlines for 2007 transfer pricing documentation, expands scope of ‘related party’ definition
- IRS expands scope of advance pricing agreements to cover permanent establishment issues
- Canadian court dismisses government motion in GE case
- South Africa debates scope of changes to transfer pricing regime
- Turkey introduces transfer pricing documentation rules for taxpayers in free trade zones
April/May 2008
IRS issues industry directive on cost sharing February/March 2008
Transfer pricing reform in Russia: a change of course December 2007/January 2008
IRS releases coordinated issue paper on cost sharing buy-in adjustments October/November 2007
Canada-U.S. protocol institutes binding arbitration procedure: it’s finally time to play ball |
