HLB TRANSFER PRICING NEWSLETTER (FEBRUARY 2010)
Welcome to the fourth HLB International Transfer Pricing Group newsletter. The Transfer Pricing newsletter is an initiative by the HLB Tranfer Pricing Group represented by members of HLB International worldwide. The group is chaired by Fiona Cross, Vantis plc., UK.
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Roche Products Pty Limited v Commissioner of Taxation
The preliminary and final decisions of the Australian Administrative Appeals Tribunal in the case of Roche Products Pty Limited v Commissioner of Taxation represent the first substantive Australian court or tribunal decisions concerning the practical operation of Australia's transfer pricing tax provisions. Lessons can be taken from these decisions that apply not only to Australia but also to other jurisdictions.
Follow-up: Documentary Obligation
1. Entry Into force: Transfers carried out as of 1 January 2010 by French companies or French permanent establishments of foreign companies.
Transfer of intangible goods between related parties usually proceeds in three different ways: contribution to capital, sale or licence. Probably the most common, yet the most challenging to transfer pricing issue is licensing.
Transfer pricing has become an increasing issue at the Danish Tax Administration. Task forces have been established with some success. Danish holding companies have been used within an international group to optimize the flow through of income, i.e. to reduce withholding taxes and income taxes in other jurisdictions than the ultimate beneficiary company.
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Last Updated on Friday, 26 February 2010 18:22