International transfer pricing update - April 2012
Indian Budget measures and an update on US transfer pricing controversy
"The Indian topic was very relevant and well presented with up-to-date opinions." - VP Tax and Treasury, Technology
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Transfer pricing proposals in the Indian Budget announcement for 2012
- Introduction of advance pricing agreements
- Expansion of transfer pricing provisions to domestic transactions
- Procedural amendments (powers of the transfer pricing officer, tolerance range, extension of time limits, penalty provisions)
- Business impact and key considerations: compliance and litigation.
Vijay Iyer, Ernst & Young Pvt. Ltd., Partner and National Transfer Pricing Leader, India
US Transfer Pricing Controversy Update
- IRS Large Business & International ("LB&I") transfer pricing organizational changes
- New Advance Pricing and Mutual Agreement ("APMA") Program (integration of APA and Competent Authority)
- Transfer pricing issues the IRS is focusing on
- Final cost sharing regulations (including pending withdrawal of the cost sharing coordinated issue paper)
- Joint audits
David Canale, Ernst & Young LLP (US), Principal and Americas Director of Transfer Pricing Controversy Services, USA
John Hobster, Ernst & Young LLP (UK), Partner, Head of Global Accounts – Transfer Pricing and Tax Effective Supply Chain Management.