The Brazilian tax authority has released an opinion which states that expenses, relating to shared services between related entities, may be considered tax deductable for the Brazilian company benefitting from the service and applicable for a reimbursement.
The French tax authorities have officially announced the creation of a new group to deal with its advance pricing agreements (APA) and mutual agreement procedures (MAP).
The Internal Revenue Service (IRS) has released a roadmap for transfer pricing audit designed as a reference tool for taxpayers involved in typical 24-month audits.
HM Revenue & Customs (HMRC) has been targeting mid-sized companies’ transfer pricing arrangements and has increased its yield over the 2012 to 2013 accounting period by more than £100 million ($164 million) on the previous year. But small and medium-sized enterprises (SME) are not keeping pace with HMRC’s focus.
Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implications, which must be considered by any multinational in this position.
