Mention Brazil and transfer pricing and the eyes of multinational taxpayers begin to roll. Brazil’s approach to transfer pricing legislation is notoriously different to that of the OECD and this causes obvious compliance issues for taxpayers but, is its approach necessarily a bad one in principle?
A Vietnamese official has blamed the inexperience of the tax authorities for the country’s failure to keep on top of multinational enterprises’ (MNE) transfer pricing.
The most recent high-level hire in the OECD’s Centre for Tax Policy and Administration (CTPA) has reiterated the department’s commitment to transfer pricing development, naming it as its highest priority.
The Spanish Supreme Court has made a decision which not only contrasts with that of France's Zimmer case and Norway's Dell case but means taxpayers should re-examine structures where a Spanish company performs activities for non-resident related entities under contract.
The Supreme Court of Canada met in January to hear the Canada Revenue Agency's (CRA) appeal and GlaxoSmithKline's (GSK) response in a case about whether the taxpayer paid too much for active pharmaceutical ingredients (API) from a Swiss associated enterprise.
