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

UN issues Preamble clarifiying that country views in TP Manual 'not its own'

UN issues Preamble to Chapter on Country Practices in TP Manual for Developing Countries; Clarifies that views expressed by countries (including India) do not reflect UN's views

Oct 15, 2012

What the US Senate heard about offshore profit shifting

US Senate conducts hearing on Offshore Profit Shifting and US Tax Code on Sept 20; Highlights sale / licensing of intangible property to low-tax jurisdictions and repatriation techniques as primary

Oct 15, 2012

OECD publishes comments on 3 transfer pricing discussion drafts

OECD publishes public comments on 3 discussion drafts on TP aspects of intangibles, safe harbour and timing issue 

Oct 05, 2012

UN publishes TP Manual; Compensate entities incurring excessive AMP expenses, says India

UN publishes Transfer Pricing Manual for developing countries; Manual includes discussion on administrative and technical issues relevant for developing countries; Internal comparables preferable over external comparables, subject to 'rigorous scrutiny';

Oct 04, 2012

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