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Transfer Pricing

288 published works

  1. 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…

  2. China Law Update Blog

    Multinational Companies Could Face Stricter Transfer Pricing Investigation By Chinese Tax Authorities

    By Sheppard Mullin

    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…

  3. China Law Update Blog

    China Enhances Supervision of Cross-border Related Party Transactions

    By Sheppard Mullin

    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…

  4. 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…

  5. Corporate & Securities Law Blog

    Update – Mexico Takes Action Against CPAs In Enforcing Transfer Pricing Rules

    By Sheppard Mullin

    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…

  6. Corporate & Securities Law Blog

    China Expands Transfer Pricing Audits

    By Sheppard Mullin

    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…

  7. Corporate & Securities Law Blog

    Migrating Intangibles Offshore – Don’t be Caught with a Transfer Pricing Assessment

    By Sheppard Mullin

    This past week, Symantec Corp., the maker of Norton AntiVirus software, received a $1 billion tax assessment for improper transfer pricing. The IRS alleges Symantec undervalued a license agreement with…

  8. Corporate & Securities Law Blog

    Mexico Increases its Focus on Transfer Pricing Through Tax Audits and Financial Statement Review

    By Sheppard Mullin

    After the Organization for Economic Cooperation and Development criticized Mexico for an inadequate number of transfer pricing audits, Mexico agreed to correct the problem.  In 2004, Mexico's Finance Ministry split…