Transfer pricing and tax-effective supply chain management - Ernst & Young - United States

Thought leadership

EY Russia (Transfer Pricing), Advanced Pricing Agreement Guidelines published in Russia
24 January 2012
The letter is a recommendation, and although it is not binding for taxpayers, it provides guidance on the practical realization of an Advanced Pricing Agreement (APA) tool provided by Chapter 14.6 of the Tax Code.

IRS will withdraw 2007 coordinated issue paper on cost sharing buy-in transactions
24 January 2012
Speaking at a Pacific Rim Tax Institute conference on 19 January, IRS Transfer Pricing Director Samuel Maruca has announced that the IRS will withdraw its 2007 coordinated issue paper, LMSB-04-090762, (the CIP) addressing buy-in payments for intangible property made available to cost-sharing arrangements (CSAs).

Hong Kong plans to start accepting bilateral advance pricing arrangement requests
20 January 2012
On 3 January 2012, the Hong Kong Commissioner of the Inland Revenue announced during a seminar that the Inland Revenue Department (IRD) will launch an advance pricing arrangement (APA) program, with plans to start accepting applications from April 2012.

IRS LB&I issues Competent Authority Statistics
19 January 2012
The Internal Revenue Service (IRS) released the Large Business & International (LB&I) Division FY 2011 Competent Authority Statistics Report on 16 December 2011.

EY Canada (Transfer Pricing), Supreme Court of Canada hears GlaxoSmithKline case
16 January 2012
On 13 January 2012, a seven-member panel of the Supreme Court of Canada heard the appeal of the Federal Court of Appeal’s (FCA’s) decision in favour of Glaxo Canada in the GlaxoSmithKline transfer pricing case.

EY Vietnam (Transfer Pricing), Vietnam proposes amendments to transfer pricing regulations, other tax changes
12 January 2012
Pursuant to the recently approved Tax Reform Strategy for 2011 to 2020, Vietnam’s Ministry of Finance (MOF) released a draft amending the Law on Tax Administration.

EY HK (Transfer Pricing), Hong Kong IRD to start accepting BAPA requests
6 January 2012
In 2009, the Hong Kong Inland Revenue Department (the HKIRD) released two transfer pricing related Departmental Interpretation and Practice Notes (DIPN).

EY Hungary (Transfer Pricing), Hungary’s transfer pricing update
5 January 2012
Transfer pricing documentation rules have existed in Hungary since 2003. Besides the implementation of the EU code of conduct on documentation, the end of 2011 brought about the most significant changes to date in the Hungarian regulations.

EY Macedonia (Transfer Pricing), Macedonian Ministry of Finance issues new corporate taxation guidelines
5 January 2012
The Ministry of Finance issued on 15 December 2011 interpretative guidelines on the new corporate income tax law passed last April and discussed in our March 2011 Tax Alert.

EY Brazil (Transfer Pricing), Brazil: Transfer Pricing — relief provided for export transactions for
5 January 2012
Brazilian federal tax authority issued Portaria 563/2011 on 28 December 2011 and Normative Instruction 1.233/2012 on 3 January 2012, which allows the application of an adjustment mechanism on the transfer prices on export transactions to related parties.

EY Hungary, Transfer pricing – new documentation rules
30 December 2011
Decree No. 22/2009 (X. 16.) of the Ministry of Finance has been amended effective from 1 January 2012. The majority of the amendments aims for simplifi cation and hence, the administrative burden should decrease.

IRS adopts final cost sharing regulations
22 December 2011
On 16 December 2011 the IRS released new final regulations under Section 482 (Treas. Reg. Section 1.482-7 or the final regulations) governing cost sharing arrangements (CSAs).

Indonesia amends transfer pricing regulations
8 December 2011
On 11 November 2011, Indonesia’s Director of Taxation amended its transfer pricing regulations that were issued 6 September 2010.

EY Hong Kong, (TP/FS), Interaction of regulatory change and financial services transfer pricing in Asia
1 December 2011
On 14 November 2011, Ernst & Young's Hong Kong Financial Services Transfer Pricing (FSTP) team hosted a transfer pricing seminar discussing the impact of recent regulatory change on transfer pricing in the region.

EY Canada (Transfer Pricing), Highlights from the Canada Revenue Agency 2010–11 APA Program Report
28 November 2011
The report provides an overview of the operations of the APA program, including statistical analyses of APAs completed and in progress.

EY Indonesia, Special Transfer Pricing Alert
25 November 2011
On 23 November 2011 the Director General of Taxation released PER 32/PJ2011 dated 11 November 2011, amending PER 43/PJ2010 dated 6 September 2010, on the application of the arm's length principle on transactions between parties that have a special relationship.

EY Angola (Transfer Pricing), Angola proposes transfer pricing documentation rules
21 November 2011
A draft legislation package has been issued that includes significant new rules for Angolan taxpayers concerning transfer pricing. This legislation is proposed to be inserted in the Statute of Big Taxpayers, which establishes, among other aspects, declarative and administrative obligations for such taxpayers.

EY Australia, Transfer Pricing Insight - Changes to transfer pricing laws and increased ATO scrutiny
10 November 2011
Current legislative proposals and planned transfer pricing administration initiatives by the Australian Taxation Office (ATO) will have a significant and cumulative impact on the transfer pricing landscape in Australia.

Colombia eliminates restrictions on foreign debt; intercompany loans now possible
10 November 2011
On 28 October 2011, the Board of Directors of the Colombian Central Bank issued rules that loosen the restrictions on foreign debt, which will provide flexibility to companies operating in Colombia.

Recent changes to the Japanese transfer pricing regime
7 November 2011
On 1 October 2011, a number of changes to the Japanese transfer pricing legislation came into effect. Many of these changes along with other recent changes have the purpose of aligning Japanese legislation with the updated OECD Guidelines.

US Customs solicits comments on new policy related to affect of post-importation transfer pricing adjustments on transaction value
28 September 2011
In a significant development in customs valuation and transfer pricing, the US Customs and Border Protection ("CBP") is considering a change regarding the impact of post-importation price adjustments on transaction value.

New legislation in Israel excludes certain related party financing transactions from application of transfer pricing rules
9 September 2011
On 3 August 2011, the Israeli Parliament enacted amendment 185 (the Amendment), which excludes certain related party finance transactions from the application of transfer pricing rules.

Archive

Why transfer pricing still dominates the tax agenda
Read about six major trends in transfer pricing that keep tax professionals up at night. Also, what are four things multinationals should do differently in regards to transfer pricing? Learn more from our recent survey.

Webcast: Managing transfer pricing risks
Our panelists addressed how corporate tax professionals are dealing with the economic, regulatory and fiscal changes taking place in transfer pricing around the world.

Ernst & Young Transfer Pricing practice recognized
Ernst & Young's Transfer Pricing practice was recently recognized by Euromoney's International Tax Review publication as the "Canada Transfer Pricing Firm of the Year" for the third year in a row. The awards are presented on a national basis, except for the US, where firms vied for Tax Firm of the Year and Transfer Pricing Firm of the Year in six markets. Besides naming the Canada Transfer Pricing practice as the best, International Tax Review also awarded Firm of the Year distinction to Ernst & Young LLP's Transfer Pricing practices in Houston, Dallas and Chicago.

Purvez Captain, Americas Director of Transfer Pricing Economics and Services, noted that "this is great recognition of the hard work and dedication of our Transfer Pricing professionals across the Americas. Their commitment to excellence sets the standard in transfer pricing leadership recognized by the market."

International Tax Review also awarded the member firms of Ernst & Young the North America Indirect Tax Firm of the Year award.

Ernst & Young takes transfer pricing practice to new heights
Added bench strength comes as increased audits, penalties and tax controversy anticipated.

July 2010 FSTP worldwide
Financial services transfer pricing insights

• Expatriate multinational-assignments
• Regulatory restrictions on permanent establishments
• Year-end bonus trigger regulatory issues
• Parent affiliation and credit ratings
• Transfer pricing in Ireland
• German public ruling and resistance to ECJ
• Transitioning to IFRS

Archive

Transfer Pricing University

Ernst & Young Transfer Pricing University courses are taught by our leading national and local office transfer pricing professionals. Continuing professional education (CPE) credit is earned for each module completed. The full program consists of three modules, plus one module specifically for financial services professionals. The following courses are offered in Ernst & Young offices around the US throughout the year.

• Transfer Pricing 101 - The basics of transfer pricing
• Transfer Pricing 201 - Intermediate transfer pricing
• Transfer Pricing 301 - Advanced transfer pricing

Financial Services Transfer Pricing – A course specific to the financial services industry

All courses are complimentary; there is no registration fee or materials cost. Contact your local Ernst & Young Transfer Pricing professional or ITS.Marketing@ey.com for course schedules and program details. Let us help your in-house team achieve its potential.