Transfer Pricing Insider

Volume 2, Issue 3

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Making Better Use of APA and MAP Programs

Source: WG&L Journal of International Taxation

By not taking frequent action, the company may expose itself to difficult debates with respect to financial accounting, issues of formal tax laws (notably, burden of proof), and deadlines for MAPs. Therefore, a shortage of internal resources may backfire in the long run. (November 2008) <Read More>

Transactional Profit Methods Renewed Focus on Comparability Analysis?

Source: Batanyl Katongera, Senior Manager, ONESOURCE Transfer Pricing, Thomson Reuters

A review of the draft work of the Working Party No. 6 ("WP6") of the OECD Committee on Fiscal Affairs into the application of Transactional Profit Methods, reveals that is appears there may soon be an increased focus by OECD member country tax authorities on the comparability analysis (including functional analysis) in transfer pricing documentation. <Read More>

Ernst & Young Foreign Desk Roundtable: A Comparative Tax Tour of Asia

Source: WG&L Journal of International Taxation

Asia's tax system has many nuances that differ significantly from those in North America and Europe. To help define and understand these nuances and their impact on countries doing business with Asia, Ernst & Young LLP recently brought together the U.S.-based Foreign Tax Desks from Asia who have firsthand experience of the countries and understand the needs of U.S. multinational enterprises (MNEs) operating there. (November 2008). <Read More>

Technical Explanation Clarifies Protocol to Canada-U.S. Tax Treaty

Source: WG&L Journal of International Taxation

Under a new rule in the Protocol, the cross-border provision of services may give rise to a PE of the service provider - the first time that the United States has included such a rule in a treaty with a developed country. (November 2008)
<Read More>

Chinese Contract Manufacturing Structures: Navigating the New Landscape

Source: WG&L Journal of International Taxation

The changes to the U.S. CFC rules and the new China CIT Law will force companies to examine intercompany pricing with related-party contract manufacturers and consider implementing new contract manufacturing arrangements, including a structure similar to the basic contract manufacturing paradigm discussed in this article. (August 2008)
<Read More>

ONESOURCE Transfer Pricing thomsonreuters.com