Transfer Pricing

Transfer Pricing News – September 2010

OECD releases 2010 transfer pricing guidelines

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Border Crossing – 2nd Quarter 2009

-  Worldwide: Transfer Pricing in times of a recession
-  China: Enforcement against tax avoidance by the PRC Tax Bureaus
-  Belgium: Participation exemption incompatible with the EC Parent-Subsidiary Directive
-  Italy: Cross-border mergers regulated
-  United States of America: Obama International Reforms announced

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Border Crossing – 3rd Quarter 2008

US: Transfer Pricing Penalties
Vietnam: Revised laws on CIT and VAT
Australia: New foreign income tax offset rules
Belgium: Location for Pan-European Pension Funds
United Kingdom: Changes Non-Domicile regime

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Border Crossing – 2nd Quarter 2008

-  Transfer Pricing Bulletin: OECD discusses the Transactional Profit Methods
-  Canada Federal Budget 2008
-  Singapore Budget 2008
-  Luxembourg: Changes to Intellectual Property rights
-  New US-Belgium Double Taxation Treaty

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Border Crossing – 4th Quarter 2007

- Transfer Pricing Bulletin: Recent Developments in China
-  UK Taxes and The Investment Manager
-  2008 Mexican Tax Reform
-  Malaysian Tax Reforms
-  New “Patent Royalties” Deduction in Belgian Tax Law

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Border Crossing – 2nd Quarter 2006

Implications Of A Transfer Pricing Audit
French Tax Alert
EU Dividends Exempt From Taxation

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Border Crossing – 3rd Quarter 2009

- Europe: Implementation of European VAT rules is rapidly approaching
– South Africa: South Africa hosts FIFA World Cup 2010
– United States: The battle between taxpayers and the Internal Revenue Service over access to tax computation working papers
– Ireland: Key taxation measures in developing a smart economy
– United Kingdom: New disclosure facilities in the United Kingdom
– Argentina: Transfer Pricing in Argentina

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Border Crossing – 3rd Quarter 2007

-  Transfer Pricing Bulletin: New regulations limit intercompany allocations of service costs
-  China: New Corporate Income Tax Law
-  Belgium: The new notional interest deduction in Belgium; a success story?
-  Indonesia: Changes to Article 23 Withholding Tax Rates
-  Singapore: Using Singapore as a base for investment in other countries, particularly in China and India

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