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Special Report on

Transfer Pricing Times

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The Mexican tax authority recently published new transfer pricing documentation requirements, increasing the compliance burden of both taxpayers and their independent auditors. These new requirements will allow the tax authorities to perform more targeted audits and make it easier for them to identify potential transfer pricing risks. As of now, taxpayers must file the required information by June 30, 2009. However, there is still a chance that these requirements may be modified, postponed, or even cancelled as a result of negotiations between the Mexican Accounting Bar and the tax authorities. Information requirements The new ...
refers to a tax imposed on entities that are taxed at the entity level in a particular jurisdiction. Such taxes may include income or other taxes. The tax systems of most countries impose an income tax at the entity level on certain type(s) of entities (company or corporation ). Many systems additionally tax owners or members of those entities on dividends or other distributions by the entity to the members. The tax generally is imposed on net taxable income . Net taxable income for corporate tax is generally financial statement income with modifications, and may be defined in great detail within the system. The rate of tax ...
India-US Competent Authorities negotiated on transfer pricing ...
Recent negotiations between the Competent Authorities (CAs) of India and the USA under Article 27 of the India-US tax treaty (Tax treaty), which deals with the Mutual Agreement Procedure (MAP), provides for a dispute resolution mechanism where the CAs shall endeavor by mutual agreement to resolve the situation of taxpayers subject to taxation not in accordance with the provisions of the Tax Treaty. A Memorandum of Understanding (MoU) between the two countries provides that the CAs would endeavor to resolve such disputes within a period of two years and also provides for obtaining a stay on collection of the disputed taxes during ... market research, surveys and trends
Zambia starts copper mine audits to verify earnings |
Finance Minister Situmbeko Musokotwane and LAP Green Managing Director Abdulbaset Elazzabi congratulate each other after a successful hand over of 75 per cent share of Zamtel to LAP Green in Lusaka Zambia is conducting an audit of mining companies to determine their earnings and will punish companies found cheating over declaration of revenues, Finance Minister Situmbeko Musokotwane said on Saturday. Musokotwane said the southern African country, the continent’s largest copper producer, was also on course to produce 700,000 tonnes of copper this year following a rebound in metals output at the mines and a rally in global ... market research, surveys and trends


Ceteris | Transfer Pricing Times, Volume IV Issue 2 | Tax ...
The OECD’s Committee on Fiscal Affairs issued a report in February that may reduce the risk of double taxation. The report, entitled “Improving the Resolution of Tax Treaty Disputes”, modifies the Model Tax Convention to propose that issues remaining unresolved by competent authorities for two years be submitted to arbitration upon the request of the person who submitted the case. The Model Tax Convention is a document on which most OECD countries base their processes for negotiation during tax disputes. Prior to the release of the February report, countries relied on a “mutual agreement procedure”, ... industry trends, business articles and survey research
agreed to pay more than $3 billion in taxes and interest covering tax years from 1989 to .... the median profit margin is less than or equal to seven percent. ..... Transfer Pricing Times 4, no. 6. Chung, K., and Richard McAlonan. 2007. ... industry trends, business articles and survey research
Tax Dodgers, Inc.
Financial professionals work in the Goldman Sachs booth on the floor of the New York Stock Exchange near the end of the trading day May 4, 2010 in New York City. (Photo by Chris Hondros/Getty Images) Firms abuse transfer pricing by shifting costly assets from places like the United States to low or no-tax jurisdictions, say, Luxembourg or the Bahamas. As the saying goes, two things in life are certain: death and taxes. Unless you’re a multinational corporation. In that case, if you’re on the brink of death—and “too big to fail”—the government might bail you out. As for taxes, the federal code ... market trends, news research and surveys resources
ParkerVision to Supply RF Chipsets for 3G Mobile Handset Design Win
announced today that it has entered into an agreement with its confidential baseband partner to supply RF chipsets that incorporate ParkerVision's d2p(TM) technology, for a 3G mobile handset design win. The agreement includes negotiated pricing and other terms for the baseband partner's purchase of one million RF chipsets from ParkerVision. The chipsets will be used with baseband processors sold to a leading mobile handset OEM, who is a significant customer of ParkerVision's baseband partner. ParkerVision developed its chipset in conjunction with its baseband partner, a global supplier of mobile handset and data ... market trends, news research and surveys resources


Transfer Pricing Brochure Final
Ceteris Group Transfer Pricing Times, Volume III, Issue 6. DAY TWO. Wednesday, 11 February 2009. DAY TWO. Wednesday, 11 February 2009 ... technology research, surveys study and trend statistics
Prepared Remarks of IRS Commissioner Doug Shulman to New York ...
WASHINGTON — It’s a great honor to address the New York State Bar Association Taxation Section. I look forward to beginning a dialogue with you that will start – but I trust – not end today. Today, I want to discuss complexity…and more to the point, how we are trying to work smarter to manage complexity. Complex systems abound…from the structure of nature itself… to  global economies and international trade…to legal systems…to our own complicated daily lives that seem to defy simplification.  Complexity has become a whole field of study and even a cottage industry for authors and consultants trying to make sense of complex ... technology research, surveys study and trend statistics
Financial Times How transfer pricing threatens global tax revenues
Jul 21, 2004 ... Financial Times. How transfer pricing threatens global tax revenues. John Plender and Martin SimonsPublished: July 21 2004 21:35 | Last ...
  1. profile image xianyou99t Transfer pricing perspectives - Thriving through challenging times
Minimum transfer pricing
Best Practices, Inc., is a management consulting firm. Its Corporate Division advises private firms on the adoption and use of cost management systems. Government Division consults with state and local governments. Government Division has a client that is interested in implementing an activitybased costing system in its public works department. The division’s head approached the head of Corporate Division about using one of its associates. Corporate Division charges clients $300 per hour for associate services, the same rate other consulting companies charge. The Government Division head complained that it could hire its ...
In tough budgetary times, how do you continue to provide ongoing ...
Every manager and almost every member of staff is a potential trainer to their colleagues - they all have knowledge, experience and skills to share, just give them the time and incentive to do so. posted 1 month ago Hi Rosetta, I think a lot of organizations overlook the extraordinary potential inherent in their current workforce. Mentoring and on-job-training cost little, have very good ROI, represent a concrete way of valuing employee skills and talent, and help create an environment that leads to a learning culture within the organization. Once implanted, mentoring and OJT programs become organic - they tend to scale ...