Increasing participation of Multinational Enterprises (MNEs) in economic activities has given rise to new and complex issues emerging from transactions entered into between two or more enterprises belonging to the same multi-national group.

Transfer pricing is an effective corporate tax tool for tax department managers to understand the level of tax risks associated with each transaction and plan future actions. Moreover, with a proper international tax planning and transfer pricing strategy, MNEs can increase their cash flows and reduce their overall effective tax rates (ETRs).
 
Currently, most countires have transfer pricing regulations, which follow the arm's length principle to determine MNE taxable profits. When it comes to compliance perspective, MNEs that are not in compliance might face double taxation, penalties and/or transfer pricing adjustments. Let our team of experts solve all your transfer pricing issues.
 
Click on each announcement news for a link to the full article

February, 2010 - Brazil introduces changes to its transfer pricing legislation
* Replacement of the resale minus methods for a single method -Sale minus profit method;
* Mark-up of 20% and 60% replaced by a 35% mark-up

February 4, 2010 - Ireland

Under pressure from countires who view the country as a soft touch for aggressive tax plannnig, Ireland will probably introduce new transfer pricing rules when the Finance Bill 2010 is published.

March 26, 2009 - Russia
Russian Transfer Pricing Rules on the verge of change.

January 15, 2009 - Chinese Transfer Pricing Regulations

Greatly anticipated Chinese transfer pricing regulations (English translation)

December 31, 2008
the IRS issued new cost sharing regulations in temporary and proposed form.

August 1, 2008 - IRS

IRS issued final and temporary transfer pricing services regulations. 

July 17, 2008 - OECD
OECD Council approved the release of the final version of the Report on the Attribution of Profits to Permanent Establishments.

July 1, 2008 - ALR launches website

ArmsLengthRange is proud to launch its new website, offering clients new services and information on the subject of transfer pricing. 





 
 
 
 
 
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