The Russian Ministry of Finance (MinFin) published a new draft transfer pricing (TP) law (144 KB)
30 October 2009
The draft law was developed by MinFin in cooperation with the Ministry for Economic Development. The new draft law is broadly in line with previous draft laws released by MinFin in 2007 though it also includes certain elements adapted from the “alternative” TP draft law sponsored by the Russian Union of Entrepreneurs and Industrialists (RSPP), also released in late 2007. It is expected that the new TP draft law will be submitted to the Duma (Russian parliament) during spring 2010 and the targeted introduction date is 1 January 2011.
Hungarian transfer pricing documentation to be simplified (795 KB)
23 October 2009
Many analyses of international tax systems compare the US to the OECD countries. While being readily available, these comparisons necessarily include a number of small countries that are not headquarters to any major global competitors of US companies. In addition, these OECD-based comparisons omit some important emerging economies that are headquarters to significant global competitors. Accelerating globalization is changing the competitive landscape for US companies, but that competition isn’t from companies headquartered in Iceland, Slovak Republic or even Ireland.
The changing landscape of headquarter locations and headquarter taxation of Fortune Global 500 companies (820 KB)
1 October 2009
Many analyses of international tax systems compare the US to the OECD countries. While being readily available, these comparisons necessarily include a number of small countries that are not headquarters to any major global competitors of US companies. In addition, these OECD-based comparisons omit some important emerging economies that are headquarters to significant global competitors.
OECD releases a draft of updated transfer pricing guidelines (171 KB)
18 September 2009
On 9 September 2009, the Organisation for Economic Co-Operation and Development (OECD) released a Proposed Revision of Chapters I-III of theTransfer Pricing Guidelines (Draft).
IRS issues third field directive on Section 936 exit strategies (2444.06 KB)
28 August 2009
On 14 August 2009, the IRS Large and Mid-Size Business Division (LMSB) issued an Industry Director Directive on Section 936 exit strategies #3 (Directive #3 or the Directive) that provides IRS examiners with further information and instructions regarding the collateral effects of Section 482 and/or Section 367(d) adjustments that arise in connection with the restructuring of Section 936 corporations.
Temporary cost sharing arrangement regulations reporting requirement clarified (148.06 KB)
6 August 2009
Each participant of a cost sharing arrangement (CSA) is required under the new cost-sharing rules to file with the IRS no later than 2 September 2009 a “Statement of Controlled Participant to Section 1.482-7T Cost Sharing Arrangement”1 (CSA Statement) regardless of whether the participant is required to file a tax return in the US. For the 2 September filing, non-US controlled participants must request an IRS tax identification number (TIN) to include with the CSA Statement.
Effective Date for Final Section 482 Services Regulations Corrected (880 KB)
5 August 2009
Tax Alert 2009-1170 erroneously reported that the final Section 482 services regulations were effective for tax years ending after July 31, 2009. In fact, the regulations are effective for tax years beginning after July 31, 2009. The corrected version of the Alert is now available.
Greece enacts transfer pricing documentation, thin capitalization rules (131.8 KB)
5 August 2009
On 14 July 2009 a new law was enacted by the Greek parliament, Transfer Pricing Documentation Rules, Thin Capitalization Rules, procedures of fast licensing and other provisions, the main provisions of which provide the: Transfer pricing and cross-border transfer pricing documentation rules
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