International Tax

Transfer Pricing: Rules and Practice in Selected Countries (H-I) (Portfolio 6955)

  • This Portfolio presents the rules and practice related to transfer pricing in Hong Kong, India, Ireland, and Italy.

Description

Chapter 70, “Transfer Pricing Rules and Practice in Hong Kong,” provides an overview of the Hong Kong Inland Revenue Department’s transfer pricing administrative practice guidance and its interaction with Hong Kong’s sourcing rules for taxation.

Chapter 75, “Transfer Pricing Rules and Practice in India,” gives the reader a basic understanding of the transfer pricing legislation and regulations in India. Indian transfer pricing rules are broadly based on the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, with some deviations, such as applying single-year data and using an arithmetic mean (rather than a range). The chapter also discusses compliance requirements, and the audit process, dispute resolution mechanisms, and Competent Authority relief and procedures. In connection with the discussion of the audit process, the chapter also considers the typical positions taken by Indian Transfer Pricing Officers on certain transfer pricing issues.

Chapter 80, “Transfer Pricing Rules and Practice in Ireland,” provides an overview of the Irish tax system and of Ireland’s transfer pricing regime, which took effect for accounting periods commencing on or after January 1, 2011. In addition, the chapter briefly summarizes Ireland’s tax audit, appeals, and litigation processes. Finally, the chapter discusses Ireland’s treaty network and procedures for preventing double taxation.

Chapter 85, “Transfer Pricing Rules and Practice in Italy,” provides an overview of the Italian tax system and administration and analyzes the main Italian transfer pricing rule, contained in Article 110(7) of the Income Tax Code, as it has been interpreted and applied over the years, under the growing influence of the OECD Transfer Pricing Guidelines. The chapter also highlights developments in the application of transfer pricing rules to domestic transactions and analyzes specifically the transfer pricing issues applicable to selected transactions, together with the growing administrative practice and case law.

Description

Chapter 70, “Transfer Pricing Rules and Practice in Hong Kong,” provides an overview of the Hong Kong Inland Revenue Department’s transfer pricing administrative practice guidance and its interaction with Hong Kong’s sourcing rules for taxation.

Chapter 75, “Transfer Pricing Rules and Practice in India,” gives the reader a basic understanding of the transfer pricing legislation and regulations in India. Indian transfer pricing rules are broadly based on the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, with some deviations, such as applying single-year data and using an arithmetic mean (rather than a range). The chapter also discusses compliance requirements, and the audit process, dispute resolution mechanisms, and Competent Authority relief and procedures. In connection with the discussion of the audit process, the chapter also considers the typical positions taken by Indian Transfer Pricing Officers on certain transfer pricing issues.

Chapter 80, “Transfer Pricing Rules and Practice in Ireland,” provides an overview of the Irish tax system and of Ireland’s transfer pricing regime, which took effect for accounting periods commencing on or after January 1, 2011. In addition, the chapter briefly summarizes Ireland’s tax audit, appeals, and litigation processes. Finally, the chapter discusses Ireland’s treaty network and procedures for preventing double taxation.

Chapter 85, “Transfer Pricing Rules and Practice in Italy,” provides an overview of the Italian tax system and administration and analyzes the main Italian transfer pricing rule, contained in Article 110(7) of the Income Tax Code, as it has been interpreted and applied over the years, under the growing influence of the OECD Transfer Pricing Guidelines. The chapter also highlights developments in the application of transfer pricing rules to domestic transactions and analyzes specifically the transfer pricing issues applicable to selected transactions, together with the growing administrative practice and case law.

cheung_patrick_2015
Patrick Cheung
Partner
Deloitte Touche Tohmatsu
coronado-luis-2015
Luis Coronado
Partner, Asia Pacific Transfer Pricing Leader - International Tax Services
Ernst & Young Solutions LLP
Samir Gandhi
Partner
Deloitte India
Minal_Sharma
Minal Sharma
Manager, Transfer Pricing
Deloitte Haskins & Sells
Rakesh_Alshi
Rakesh Alshi
Partner
Deloitte Haskins & Sells, Chartered
Stark_Sanford
Sanford Stark
Partner
Morgan, Lewis & Bockius LLP
armitae-j-clark-2015
Clark Armitage
Caplin&Drysdale
Mezei_Saul
Saul Mezei
Partner
Morgan, Lewis & Bockius LLP
galli-carlo-2015
Carlo Galli
Partner
Clifford Chance
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