The Danish tax authority, SKAT, has published its transfer pricing statistics, which show an increase in revenue from transfer pricing assessments, particularly through intellectual property (IP) transactions.
HM Revenue & Customs (HMRC) has said it does not expect to see a link between the tax demanded and yield achieved in transfer pricing assessments and does not keep records to attempt to link them.
The LG tax ruling in India, on the transfer pricing aspects of marketing intangibles, is a shot in the arm for the Indian authorities because the Income Tax Appellate Tribunal (ITAT) deems, when the taxpayer incurs higher advertising, marketing and promotion (AMP) expenses to comparable companies, it is creating or enhancing a brand owned by the foreign entity and should be remunerated on a cost-plus basis. Some taxpayers are not surprised by the verdict however and have said it has an up-side.
International Tax Review provides taxpayers with in-depth analysis of developments in Brazil, Russia, India, China and South Africa (BRICS), along with the rest of the world.
The BRICS are steadily earning their place in international transfer pricing policy. With strong economies, investment in and out of the BRICS is constantly growing.
The BRICS countries’ (Brazil, Russia, India, China and South Africa) tax authorities have agreed to exchange information to strengthen their tax systems, including India helping South Africa to implement an advance pricing (APA) regime.
