Festive sales 'will start early' Nov 19, 2009
FROM OTHER NEWS SITES Debenhams Seeks Head Start With Pre-Xmas Sale - 1 hr ago Tax team of the year: BDO Transfer Pricing - 6 hrs ago * Good to grow: why Bolland is right choice for M - 9 hrs ago * Requires registration. SHARED. (BBC News -- Business)
Tax BPO at 11-13% over cost: Deloitte Nov 18, 2009
A safe harbour would essentially mean circumstances in which, the Indian revenue Authorities shall accept the transfer pricing declared by the taxpayer. Transfer pricing provisions in general require income arising from an international transaction between two or more related organisations to be calculated at an arms length price or at a price comparable to similar transactions between unrelated parties ... India had introduced transfer pricing norms in 2001 but complexity has... (India Times)
Multinational Corporations And The Developing World Nov 15, 2009
One unique way that an MNC can do this is through the process know as transfer pricing. This enables the MNC to reduce its profits in countries with high rate of profit tax, and increase them in countries with low rates of profit tax. (Ghana Web, Ghana)
FRS 139 and its bearing on transfer pricing Nov 11, 2009
Following the introduction of Section 140A of the Income Tax Act 1967 (ITA) which basically requires taxpayers to ensure that their related party transactions are carried out at arms length, would this then mean that an assessment of the fair value of related party loans by the auditors under FRS 139 can serve as contemporaneous documentation for transfer pricing purposes ... Since 2003, transfer pricing guidelines have been issued, setting out the extent of information required in a transfer... (The Star Online, Malaysia -- Business)
'Different opinion no ground for penalty' Nov 10, 2009
MUMBAI: The Delhi Income-tax Appellate Tribunal (ITAT) has held that difference of opinion cannot be a ground for 00004000 levying penalty in transfer pricing issues ... The adjustments were on the premise that these are extraordinary costs that need to be excluded while estimating arm's length price under transfer pricing regulations ... The transfer pricing officer, however, rejected the third adjustment on the premise that provision for doubtful expenditure could not be construed... (India Times)
MNCs face greater transfer pricing scrutiny Nov 2, 2009
KUALA LUMPUR: Multinationals are facing new tax challenges due to growing transfer pricing (TP) scrutiny by worlds tax authorities, according to a survey ... As governments search for tax revenues to offset growing budget deficits, many are sharpening their focus on compliance, enforcement and legislative approaches, said Ernst Malaysia partner and head of transfer pricing, Janice Wong. (The Star Online, Malaysia -- Business)
Taxing times ahead for foreign BPOs Oct 24, 2009
For the IT-BPO industry transfer pricing is the main issue and this is being addressed by the government through safe harbour provisions being made. Overall, we have to create an environment which makes it easier to do business with and in India. (India Times)
The taxing issue of doing business in China Oct 19, 2009
" China may be regarded as a paradise for cheap manufacturing and wealth creation, but can also be a business hell if you get it wrong. China now has a 25 per cent unified tax rate as well as additional indirect taxes, such as a five per cent business tax (a surcharge on certain types of profits) with a very strict enforcement regime, says Peter Godber, National Head of Taxation Services at Grant Thornton. Many entrepreneurs may be unaware of the new tax changes which have come about since laws... (Sydney Morning Herald -- Business)
READ: Bank of American's press release Oct 17, 2009
" Third-Quarter 2009 Business Highlights -- Average retail deposits in the quarter increased $93.0 billion, or 16 percent, from a year earlier, including the net impact of $72.1 billion in balances from Merrill Lynch and Countrywide. Excluding Countrywide and Merrill Lynch, retail deposits grew $20.9 billion, or 4 percent, from the year-ago quarter. -- Global Wealth and Investment Management was ranked No. 1 among U.S. wealth managers with more than 25 percent of the nation's top 100 financial... (USA Today -- Money)
Full text of Vodafone Review Report released by the government Oct 17, 2009
There is evidence that Vodafone International BV seems to have ceded its role to Vodafone PLC and can be a ruse way of wanting to practice the phenomenon of transfer pricing and the Internal Revenue Service must be alerted. Accordingly, the Committee made the following recommendations to Government. (Ghana Web, Ghana)
Botswana: A Political Novice With Ambition Oct 17, 2009
He says the government is not aware of the mineral transfer pricing. He stresses the need for strong and qualitative education. (allAfrica.com)
New rules on tax disputes to guide foreign firms Oct 16, 2009
Globally 60% of tax disputes are on transfer pricing (price at which an organisation transfers goods from one arm to another). In India, too, transfer pricing related tax disputes are rising day by day, said Mr Ved. (India Times)
Budget unlikely to dish out many goodies to man in the street Oct 14, 2009
Poon said the seminar would cover budget updates, tax cases, field audits, tax investigations, transfer pricing risk assessment and issues on reinvestment allowance (RA). We will also be advising more effective tax planning for small and medium enterprises (SMEs) and corporations. (The Star Online, Malaysia -- Business)
How Do Tax Havens Work? Oct 11, 2009
Transfer pricing: changing the prices of goods and services sold to company affiliates to shift income from high-tax jurisdictions. Similarly, companies have transferred intellectual property or intangible assets to tax havens. (Suite101.com)
Paradis Fiscaux: Inside the tax haven Oct 10, 2009
Companies trading internationally often take recourse to mispricing , transfer pricing and even fake transactions, generating millions as illegal profits. These do not appear on their individual books and can be located only by comparing accounts of all independently held subsidiaries. (India Times, India -- Intl Business)
APA for reducing transfer price disputes Sep 30, 2009
Many tax jurisdictions have recognised the significance of transfer pricing and introduced advance pricing agreement (APA) mechanism in order to address the above issues. Since the introduction of transfer pricing regulations in 2001, India, like any other tax jurisdiction, has experienced significant controversies and unresolved disputes. (India Times)
Due diligence probe is a must in current uncertain economic situation Sep 15, 2009
A tax due diligence involves looking at local and cross border tax issues and the targets compliance with tax laws, rules and regulations on, say, withholding taxes and transfer pricing. Next is the need for a legal due diligence. (The Star Online, Malaysia -- Business)
Fundamental changes ahead in tax review Sep 7, 2009
But in doing so, it also helps protect against transfer pricing, or multinational companies siphoning profits back to foreign parents. Dividend imputation is not going anywhere. (Sydney Morning Herald -- Business)
Budget 2010 what you can expect Sep 1, 2009
Deferment of implementation of onerous contemporaneous transfer pricing documentation requirements and thin capitalisation rules. These rules are inappropriate at this point in time when business conditions do not permit added costs. (The Star Online, Malaysia -- Business)
Pure Energy Services Ltd. Announces Results for the Second Quarter Ended June 30, 2009 Aug 13, 2009
The lower effective tax rate recovery is due to the impact of non-deductible expense items and amendments to the Corporation's prior years tax filings associated with adjustments to the Corporation's intercompany transfer pricing charge amounts. Liquidity and Capital Resources. (CCNMatthews Press Releases)
Appliance Recycling Centers of America Reports Second Quarter Operating Results Aug 12, 2009
The Company recorded a discrete item in the second quarter of 2009 related to additional Canadian tax deductions determined by completing a detailed transfer pricing study. The Company recognized a tax benefit of approximately $0. (PR Newswire)
STEC Announces Second Quarter 2009 Results Aug 4, 2009
" The STEC, Inc. logo is available at . Use of Non-GAAP Financial Information To supplement the consolidated financial results prepared in accordance with generally accepted accounting principles in the United States ("GAAP"), we use non-GAAP financial measures (non-GAAP gross profit, non-GAAP income from continuing operations, non-GAAP diluted earnings per share from continuing operations and non-GAAP diluted earnings per share) that exclude start-up costs related to our Malaysia facility,... (Primezone Releases)
READ THE RELEASE: Bank of America pays $713M to U.S. Jul 18, 2009
" "Most importantly, we continue to serve our customers and clients around the world every day, helping them with their accounts, meeting their financial needs and adding new business," Lewis added. Second Quarter 2009 Business Highlights -- Bank of America increased its Tier 1 common capital by nearly $40 billion through multiple actions during the quarter that included issuing shares of common stock, exchanging certain non-government preferred stock for common stock, and asset sales. -- Bank... (USA Today -- Money)
Budget offers 3-cheers to taxpayers Jul 9, 2009
The Finance Bill proposes that in respect of transfer pricing and in relation to adjustments that may be propos 00004000 ed to the income of a foreign company, instead of an assessing officer making adjustments, he would need to obtain approval from a panel of commissioners. This proposal, together with the plan to provide safe harbour for transfer pricing, will allay fears of foreign investors. (India Times)
Taxman raises the stakes on corporate tax risk Jul 7, 2009
This involves transfer pricing, a closer look at group financing arrangements (both domestic as well as cross-border) as well as complex thin capitalisation rules pending. Our system of self-assessment places on the corporate executive (who is charged with tax filing responsibility) the onerous statutory obligation of taking reasonable care, with the prospect of court sanction in the event of default. (The Star Online, Malaysia -- Business)
Battered IT boots up for a holiday Jul 7, 2009
The other is the move to set up an alternative dispute resolution mechanism for resolution of transfer pricing disputes. Formulation of safe harbour rules to reduce the impact of judgmental errors in determining transfer prices will eliminate confusion, complexity and disputes It simplifies the process of doing business, with its moves on transfer pricing, packaged software and FBT, said Nasscom chairman Pramod Bhasin. (India Times, India)
'Advance pricing to boost offshoring' Jul 6, 2009
NEW DELHI: India should rationalise its transfer pricing norms and introduce the concept of advance pricing arrangement (APA) to retain its position as an attractive offshoring destination, a leading tax expert has said. Most multinationals want simple and rational transfer pricing norms as offshoring is essentially a thin margin business ... The comparables that are used sometimes tend to ignore this 00004000 reality, Steven E Fortier, global managing principal, global transfer pricing... (India Times)
Govt may extend tax holiday for software firms Jul 5, 2009
The other demands are abolishing minimum alternate tax (MAT) for STPIs and export-oriented units, safe harbour provisions in transfer pricing regulations, removing fringe benefit tax (FBT) on employee stock option plans (ESOPs) and no duplication of indirect taxes. At present, both service tax and value-added tax (VAT) are levied on customised software and renewing licence to use software. (India Times)
Russian Federation -- Concluding Statement of the IMF 2009 Article IV Consultation Mission Jun 16, 2009
However, a necessary precondition for such a system would be the introduction of transfer pricing legislation consistent with OECD guidelines and a strengthening of enforcement capacity. There is scope for a more accommodative monetary policy stance. (IMF News)
Q and A with Google's Marissa Mayer Jun 16, 2009
Question about reports that Google Australia takes advantage of transfer pricing arrangements to reduce its tax burden in Australia. "I'm not that familiar with the tax structure. I can't comment on the particular tax structures. I can comment on our commitment to Australia. I was in Australia last April and we have a very large and growing Australian office both in terms of engineering and sales. We have very good people there. "We're building interesting things as you can see from the Wave... (Sydney Morning Herald -- Technology)
Management fees a licence to bill? Jun 5, 2009
As a measure to withstand the potential challenges from the IRB and avoid the risk of double taxation, MCo should maintain robust transfer pricing (TP) documentation to support the management fee ... The writer is executive director (transfer pricing) with KPMG Tax Services Sdn Bhd. (The Star Online, Malaysia -- Business)
Net profits: the tax move that makes Google rich May 29, 2009
This simple transfer pricing arrangement has allowed Google to claim its Australian revenues are $90 million when the real figure is much, much larger. The problem is that no one really knows how much revenue it gets from its Australian operations. (Sydney Morning Herald -- Technology)
G20: The accounting community reacts Apr 9, 2009
It is perfectly possible for companies to publish their tax returns, details of tax avoidance schemes, transfer pricing schemes and other details. They can also publish the taxes that they pay in each country and explain why despite huge economic activity in developing countries they manage to avoid taxes. (Accounting Web, UK)
SA's stimulus package rings alarm bells about trade policy Apr 9, 2009
The revenue service is concerned about transfer pricing and has considered using a reference price system to monitor import prices to identify underinvoicing. While the objective is understandable, the practice borders on import price management - of which the WTO legality is hazy. (Business Report, South Africa)
Tax base could grow 9% in next year, says Sars Apr 2, 2009
Billy Joubert, the head of transfer pricing at Deloitte, said: "We have a much more efficient and motivated Sars now than the organisation that we had 10 years ago.". Sars was set up in 1998, following the introduction of the Sars Act the previous year, which merged the departments of inland revenue and customs and excise into an autonomous unit. (Business Report, South Africa)
Swap Prominent Hill for Harold Holt Mar 30, 2009
And "Wayne's Woomera wobbly'' makes a great headline. Besides, the whole scandal and cover up has long been such a national embarrassment you have to be careful opening up the old wounds. It's bad enough that we let our prime minister be snatched by a Chinese submarine while having a surf and didn't do anything about it, but what clown tried to paper over that by saying he drowned and Cheviot Beach sardines disposed of the body? Crikey, it's one thing to be taken by a shark or a croc or even a... (Sydney Morning Herald -- Business)
Letter from Europe Mar 20, 2009
Yet, even legal schemes like transfer pricing can lead to incoherence and crazy imbalances. There is strong evidence that in their quest to lower taxes, big companies exaggerate the output of their low-tax units and understate the exports from high-tax countries. (International Herald Tribune)
Tax fight imperils Chrysler's survival Mar 15, 2009
The Minister of National Revenue has wide discretion in determining how to handle a specific tax case, said Lorraine Eden, a transfer pricing specialist at the business school of Texas A&M University and a former professor at Carleton University in Ottawa. In this financial climate, my guess is that keeping the firm afloat and providing jobs will be more important to the Canadian government and to Canadians than any tax liability, Prof. (Globe and Mail -- Business)
Japan wants yen to be the anchor of Asia Mar 9, 2009
or finance, & 1 yr in position offered or 1 yr as analyst, transfer pricing practice or bachelor's in bus. admin. (Yahoo News -- Asian Economy)
RIL-RPL merger makes perfect sense Mar 2, 2009
RIL would save on transfer pricing on use of about-to-begin gas production from the Krishna-Godavari basin, by RPL. Estimates suggest that the advantages of the merger could add up to $1-1. 5 in gross refining margins (GRMs), which, when GRMs are under much pressure world-wide, would be notable indeed. (India Times)
PharmaNet Development Group Reports Fourth Quarter and Full Year 2008 Preliminary Financial Results Feb 26, 2009
Factors that could cause or contribute to such differences include, but are not limited to, the expected timetable for completing the proposed transaction, the risk and uncertainty in connection with a strategic alternative process, not having sufficient funds to pay the principal due upon conversion of the outstanding notes or to repurchase our outstanding notes, which we may be required to do beginning in August 2009, the impact of the current economic environment, the impact of our... (PR Newswire)
Phoenix Reports Record Financial and Operational Results for the Year Ended December 31, 2008 Feb 25, 2009
- a sales tax adjustment that was made in the fourth quarter of 2008 relating to transfer pricing updates; and. - research & development expenses increasing by 103% to $542,000 in the 2008 period from $267,000 in the corresponding 2007 period. (CCNMatthews Press Releases)
Govt to regulate minimum coal selling prices Feb 25, 2009
"Coal producers cannot sell lower than the index. "That would be good if they could sell higher than the index," said Bambang, adding that coal selling prices were likely to vary depending on the calorific values of coal and the concession location. Bambang said the index was made to help secure the anount of state revenue from coal. "The index will avoid the transfer pricing practice," Bambang said. In an earlier seminar in November last year, Bambang said the government would impose sanctions... (Jakarta Post, Indonesia -- Business)
The CPP Still Ghanas Hope Feb 25, 2009
General News of Tuesday, 24 February 2009. General News of Tuesday, 24 February 2009. (Ghana Web, Ghana)
Penalties for inaccuracies Prompted and unprompted disclosure by Rebecca Benneyworth Feb 23, 2009
Example 3During an Employer Compliance review the employer makes a disclosure that the basis of the transfer pricing calculation for Corporation Tax is wrong. This is unrelated to the subject under review and so there is an unprompted disclosure. (Accounting Web, UK)
Meta Financial Group, Inc.(R) Reports Results for First Quarter Feb 12, 2009
0 million in 2009, notwithstanding a 248 basis point reduction in the average transfer pricing yield received for its deposits from 4. 92% in 2008 to 2. (PR Newswire)
