Topic
Transfer Pricing
212 published works
European Union and Italian International Tax Law Blog
Marco Rossi of MQR&A Spoke at Chartered Institute of Taxation’s Meeting in Milan
By Marco Rossi
Marco Rossi was one of the speakers at the meeting organized by the Chartered Institute of Taxation in Milan on October 15, 2010. Marco presented on transfer pricing documentation requirements…
European Union and Italian International Tax Law Blog
Italy Enacted Rules on Trasfer Pricing Documentation
By Marco Rossi
Italy issued ruling implementing transfer pricing documentation requirements. Italian transfer pricing documentation framework largely mirrors the EU transfer pricing documentation of conduct and OECD Guidelines. Strict deadlines apply to transfer…
European Union and Italian International Tax Law Blog
Italy’s Government to Approve New Rules on Transfer Pricing Documentation, Anti Tax Abuse
By Marco Rossi
A decree presented to the Italian Council of Ministers today will introduce new provisions on contemporaneous documentation for transfer pricing purposes and a new black list with a duty to…
European Union and Italian International Tax Law Blog
Italy’s Tax Administration Published Report on Italian International Tax Ruling (APA)
By Marco Rossi
Italy's tax administration published its report on Italian international tax ruling showing 52 applications and 19 agreements signed in the first five years of the program, half of which by…
Estate & Tax Planning Musings
IRS Loses Billion Dollar Transfer Pricing Case
By Mark J. Soss
The IRS lost a billion dollar § 482 transfer pricing case yesterday. Veritas Software Corp. v. Commissioner, 133 T.C. No. 14 (Dec. 10, 2009):P entered into a cost-sharing arrangement with…
China Law Update Blog
Multinational Companies Could Face Stricter Transfer Pricing Investigation By Chinese Tax Authorities
In the beginning of 2009, the Chinese government set a target for annual tax growth of 8.2%. Due to the financial crisis, tax revenue has dropped 10.3% in the first…
China Law Update Blog
China Enhances Supervision of Cross-border Related Party Transactions
On July 6, 2009, the China State Administration for Taxation (“SAT”) issued a Notice Regarding Enhancement of Supervision and Investigation of Cross-border Related Party Transactions (the “Notice”). The Notice aims…
European Union and Italian International Tax Law Blog
Italy Authorized the Ratification of the New U.S.-Italy Tax Treaty
By Marco Rossi
Italy authorized the ratification of the new U.S.-Italy tax treaty (the "1999 Treaty"), together with a protocol and memorandum of understanding. The 1999 Treaty shall enter into force on the…
Corporate & Securities Law Blog
Update – Mexico Takes Action Against CPAs In Enforcing Transfer Pricing Rules
On May 2, 2006, we reported that the Mexican Tax Administration Service ("SAT") issued a three-month suspension of taxpayer's external auditor's license to certify financial statements. In Mexico, taxpayers of…
Corporate & Securities Law Blog
China Expands Transfer Pricing Audits
China claims that more than 50% of foreign companies which have invested in China are currently reporting losses as the result of aggressive transfer pricing. China has improved its tax sophistication and…