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Friday, June 3, 2011
BNA Tax & Accounting Transfer Pricing Report has released two Special Reports on the tax treatment of business restructurings--one on Germany and one on China.China Written by practitioners in Hong Kong and in Shanghai, "Restructuring in China: Managing Change and Uncertainty," guides readers through China's new Corporate Income Tax Rules for Corporate Restructuring and adds English translations of Chinese documents Caishui [2009] No. 59, Notice on Tax Treatment of Corporate Restructuring, and GuoShuiHan [2009] No. 363, Circular Requiring Single-Function Units with Losses to File Documentation. Germany "Germany's Transfer pricing Provisions: A Conflict with Internationally Agreed Principles?" is written by Hartmut Foerster, a member of the German government's Competent Authority staff. He compares Germany's function shifting tax rules with the Organization for Economic Cooperation and Development's work on business restructuring guidance and finds that any differences in methodology should have a relatively low relevance and should end in a roughly similar result. An English translation of the transfer pricing provisions of Germany's restructuring law and the German regulation applying arm's-length principle to function transfers is published as well. The Special Reports may be bought separately by calling 800-372-1033 in the United States or by e-mailing rmcwilli@bna.com
China
Written by practitioners in Hong Kong and in Shanghai, "Restructuring in China: Managing Change and Uncertainty," guides readers through China's new Corporate Income Tax Rules for Corporate Restructuring and adds English translations of Chinese documents Caishui [2009] No. 59, Notice on Tax Treatment of Corporate Restructuring, and GuoShuiHan [2009] No. 363, Circular Requiring Single-Function Units with Losses to File Documentation.
Germany
"Germany's Transfer pricing Provisions: A Conflict with Internationally Agreed Principles?" is written by Hartmut Foerster, a member of the German government's Competent Authority staff. He compares Germany's function shifting tax rules with the Organization for Economic Cooperation and Development's work on business restructuring guidance and finds that any differences in methodology should have a relatively low relevance and should end in a roughly similar result. An English translation of the transfer pricing provisions of Germany's restructuring law and the German regulation applying arm's-length principle to function transfers is published as well.
The Special Reports may be bought separately by calling 800-372-1033 in the United States or by e-mailing rmcwilli@bna.com
They are also available as part of a subscription to Transfer Pricing Report .
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