China: SAT is Seeking Public Comments on Consultation Draft for Implementing Special Tax Adjustments
On 17 September 2015, China’s State Administration of Taxation released a consultation draft circular concerning implementation measures for special tax adjustments that would replace the existing Guoshuifa No. 2 (Circular 2). Now the SAT is
See MoreCanada: Guidance on intra-group services published
The Canada Revenue Agency (CRA) has published Transfer Pricing Memorandum (TPM)-15 regarding intra-group services and section 247 of the Income Tax Act on 13th February 2015. TPM-15 describes the CRA’s audit policy on some audit and tax issues
See MoreIndia: Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions
In India many transfer pricing cases are heard in the Courts. These decisions can provide clarification of the operation of the transfer pricing rules in India and can therefore give potential investors more certainty about the transfer pricing
See MoreUS: Important information regarding intra-group services
The regulations of Treasury and IRS final intercompany service were issued on 31 July 2009. Some permitted transfer pricing methods for services are similar to the OECD methods but the services cost method and shared services arrangements are also
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