Emma Powell

Why South Africa’s request for TP information from the UK, US and Australia is unlikely to succeed

The South African Revenue Service (SARS) has approached the UK, US and Australia to obtain information relating to erroneous transfer pricing through complex offshore structures.

Emma Powell, June 24, 2013

How stress tests could increase related party lending

Taxpayers should be watchful of the results of the European Central Bank’s (ECB) stress tests, which could increase amounts of capital transferred between related party banks.

Emma Powell, June 19, 2013

Taxpayers should design a TP policy to bridge different practices of OECD and developing countries

Differences in guidance given by the UN and OECD transfer pricing manuals are putting taxpayers at risk of double taxation. Taxpayers should design a transfer pricing policy that acknowledges both sets of principles.

Emma Powell, June 17, 2013

Poland proposes abolishing APA annulment confidentiality

Poland’s Ministry of Finance has proposed changes to the country’s advance pricing agreement (APA) regime after reviewing the effectiveness of the programme over the past six years. However, if implemented, some proposals may reduce the popularity of the regime with taxpayers.

Emma Powell, June 12, 2013

How French taxpayers should prepare for a tougher TP regime

The French Ministry of Finance has proposed tightening the country’s transfer pricing regulation and setting tougher penalties for taxpayers who fail to comply. Advisers say the recommendations are likely to be included in a draft finance bill later this year.

Emma Powell, June 10, 2013

Japanese arm’s-length range amendments may reduce TP adjustments

The Japanese government has introduced a range of acceptable arm’s-length prices as part of a number of measures to amend the country’s transfer pricing rules. The change is likely to reduce the number of taxpayers subject to transfer pricing adjustments during audit.

Emma Powell, June 05, 2013

Emma Powell

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