Analysing BRICS' focus on tax co-operation, transfer pricing developments & information sharing

International Tax Review provides in-depth analysis of important tax developments in Brazil, Russia, India, China and South Africa (BRICS); BRICS' tax authorities promise to share information; Russia's guidance on controlled

Jan 29, 2013

New Brazilian transfer pricing law aims to cut disputes

New Brazilian transfer pricing law aims to cut disputes; Profitability threshold for exports and safe harbours raised from 5% to 10%; Taxpayer won't be able to change TP methodology once

Jan 28, 2013

Canada issues Transfer pricing memorandum endorsing OECD's 'appropriate' method selection

Canada Revenue Agency (CRA) issues interim transfer pricing memorandum endorsing OECD Guidelines of 2010; CRA approves use of 'most appropriate method' over hierarchy of methods; But highlights observations in Guidelines

Dec 14, 2012

EU Joint Transfer Pricing Forum's Report on SMEs and Cost Contribution Agreements

EU Joint Transfer Pricing Forum's Report on SMEs and Cost Contribution Agreements

Nov 05, 2012

China too advocates "location saving" & "marketing intangibles" allocation

Location savings, market premium are important TP issues for developing countries; Extra-ordinary profits due to location savings allocable to China; China would question continued royalty payments over long term and

Oct 31, 2012

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