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Special Report on

Transfer Pricing Network

transfer pricing network special research report Photo by www.kpmg.com
he transfer pricing rules are set out in section 247 of the Income Tax Act.  These provisions require that Canadian taxpayers document non-arm's-length transactions with non-residents and use arm's length transfer prices.  Permits the CRA to adjust a Canadian taxpayer's transfer prices or cost allocations where the transfer prices or cost allocations do not reflect arm�s length pricing.  Information Circular 87-2R, September 27,1999 Guidance with respect to the transfer pricing rules set out in section 247 of the Income Tax Act which received Royal Assent on 18 June 1998.
income. The manner of limitation generally takes the form of a territorial, residency, or exclusionary system. Some governments have attempted to mitigate the differing limitations of each of these three broad systems by enacting a hybrid system with characteristics of two or more. Many governments tax individuals and/or enterprises on income. Such systems of taxation vary widely, and there are no broad general rules. These variations create the potential for double taxation (where the same income is taxed by different countries) and no taxation (where income is not taxed by any country). Income tax systems may impose tax on ...
REVIEWS AND OPINIONS
yukos kingpin on trial
In mid-May a Moscow court will issue a verdict in the trial of Mikhail Khodorkovsky, the figure behind Yukos Oil, who was once known as Russia’s richest man. Khodorkovsky, who a few years ago was worth more than $15 billion, is on trial for fraud and tax evasion, much of it made possible through the use of offshore shell companies. Khodorkovsky has been in prison since 2003, when he was charged with embezzlement and for rigging a privatization auction of the petrochemical company, Apatit. Some critics argue that Khodorkovsky is being held up as a symbol of Russia’s ruling class of exorbitantly wealthy businessmen, ... market research, surveys and trends
Tax Justice Network: Transfer pricing and gold mining in Senegal
which often carries excellent financial scoops in its back pages, has a story in the latest edition (No.1620, 16 April 2010) about how Australian mining company Mineral Deposits Ltd, which extracts gold from the Sabodala region in Senegal, West Africa, and ilmenite and zircon from quarries on the Grand Cote north of Dakar, declares no profits in that country. Instead, according to Private Eye , profits are diverted to Mauritius , in the Indian Ocean, which - alas for it - has no gold, but happily for Mineral Deposits has a tax rate on corporate profits of zero percent [though according to Mauritian deputy prime minister, rumours ... market research, surveys and trends

SURVEY RESULTS FOR
TRANSFER PRICING NETWORK

cost sharing - Transfer Pricing Network
user guide is intended to help clarify the concepts and identify issues in the application of the U.S. regulations. It does not constitute legal advice, and should not be relied on as such. A. Application/Timing For all cases in which two or more related parties agree to jointly develop an intangible and both expect to derive an economic benefit once the intangible is developed, the "cost sharing" section of the 482 regulations must be considered. These regulations apply to all agreements signed after January 1, 1996, and offer a one year "Grace Period" for all agreements ... industry trends, business articles and survey research
CorpWatch : Yukos Kingpin on Trial
In mid-May a Moscow court will issue a verdict in the trial of Mikhail Khodorkovsky, the figure behind Yukos Oil, who was once known as Russia's richest man. Khodorkovsky, who a few years ago was worth more than $15 billion, is on trial for fraud and tax evasion, much of it made possible through the use of offshore shell companies. Khodorkovsky has been in prison since 2003, when he was charged with embezzlement and for rigging a privatization auction of the petrochemical company, Apatit. Some critics argue that Khodorkovsky is being held up as a symbol of Russia's ruling class of exorbitantly wealthy businessmen, and ... industry trends, business articles and survey research
RELATED NEWS
SunTrust Reports Second Quarter Results
ATLANTA, July 22 /PRNewswire-FirstCall/ -- SunTrust Banks, Inc. said today that improved asset quality and operating trends led to a significantly narrowed loss in the current quarter as compared to the prior year and the first quarter. The Company reported a net loss available to common shareholders for the second quarter of 2010 of $56 million, or $0.11 per average common share, versus a net loss of $164 million, or $0.41 per average common share, in the second quarter of 2009 and a net loss of $229 million, or $0.46 per average common share, in the first quarter of 2010. Net income before preferred dividends was $12 ... market trends, news research and surveys resources
Treasure Islands: Mapping the Geography of Corruption
When is a tax haven not a tax haven?  When Mauritius' Vice Prime Minister Ramakrishna Sithanen says so.  "We are a not a tax haven," stated Sithanen, who is also the country's Minister of Finance.  Ironically, Sithanen would go on to reveal that ring-fenced financial services (FS) -- the legal and financial secrecy vehicles facilitating corporate mispricing and corruption marketed to foreign clients, especially India -- accounts for 12.5% of GDP. Mauritius is already India's largest single source foreign investor at $39 billion, almost half of total investment flows. The beautiful tourist island of ... market trends, news research and surveys resources

INFORMATION RESOURCES

Standing out from the competition
global Transfer Pricing network for over 20 years and with the focus on quality that you would ... global Transfer Pricing network offers customised tools ... technology research, surveys study and trend statistics
Earnings Stripping, Transfer Pricing and Income Tax Treaties
Chapter III of this report is the study on transfer pricing. ..... safeguard the U.S. tax-treaty network against possible abuse in the future. The Treasury ... technology research, surveys study and trend statistics
BEYOND A TUDOR APPROACH TO TRANSFER PRICING: EVOLVING A MODEL FOR ...
latter in transfer pricing parlance is termed a 'comparable'. Since the comparable in question is obtained within Company A's transactional business network ...
REAL TIME
TRANSFER PRICING NETWORK
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QUESTIONS AND ANSWERS
Best software & hardware for book pricing?
What about the computers used by Laminar Research in the making of X-Plane? Microsoft Flight Simulator (the series) is produced by the Aces Studio which is owned by Microsoft. Do both companies use Apple Macs? I'm not sure. Tired of having to take it in every 4 to 6 months. If I were to purchase a Palm Treo 700wx (Verizon Wireless) would I be able to upgrade the phone to Microsoft's Windows Mobile 6.0 via a software update, or should I just wait for Verizon to launch a Win Mobile 6.0 device instead of buying the 700wx? Need to get educated on servers. Our small business is having growing pains and we have received ...
I need an expert on transfer pricing in China | LinkedIn Answers ...
Here is a paper on Chinese Transfer Pricing completed for my Corporate Taxation class while an MBA at Georgetown. Follow the link below. Hope it is helpful. There are some good sources in the footnotes as well which should allow you to access the most up to date commentary on TP issues. All the best, Wes Schwalje posted August 14, 2007 Owner Oleton Consultancy, experienced project manager / IT manager see all my answers Although I am not a specialist in TP-law. Whin our network in China, I can offer you the information about new TP-law, and search for a specialist in this field in Beijing or in Shanghai. Mr. Qian Tang, consultant