Topic
Transfer Pricing
288 published works
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…
Corporate & Securities Law Blog
Migrating Intangibles Offshore – Don’t be Caught with a Transfer Pricing Assessment
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…
Corporate & Securities Law Blog
Mexico Increases its Focus on Transfer Pricing Through Tax Audits and Financial Statement Review
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…