The following were originally printed in BNA Tax Management's Transfer Pricing Report, a biweekly publication.

Transfer Pricing Highlights

Volume 17 Number 1
Wednesday, May 8, 2008

U.S. Practitioners Compare German, U.S. Provisions on Restructuring

U.S. practitioners say German legislation on restructuring would represent a significant departure from both U.S. rules and Organization for Economic Cooperation and Development guidelines in requiring compensation for business opportunity when functions are moved across borders. Page 3

BP Prepares Different Levels of Documentation Based on 'Risk Weighting'

An executive with BP plc describes his company's transfer pricing policy, saying BP "risk weights" its transfer pricing transactions, supporting them with different levels of documentation depending on the risks of each transaction. In Practice, Page 25

India Moving Toward Convergence of Customs, Transfer Pricing Valuation

India's Director General of Revenue Intelligence acknowledges that the country is moving toward convergence of its customs and transfer pricing valuation mechanisms, but that it is difficult to reconcile two contrasting pricing standards. Page 12; Interview, Page 19

Official Says 22 Countries Gave China Taxpayer Information in 2007

An official says China received a total of 156 taxpayer information profiles from 22 countries in 2007, adding that China also made 27 information requests to 12 tax treaty partners that year. Page 11; Text, Page 24

Transfer Pricing in Australia: The Roche Case

Michael Jenkins of Deloitte in Melbourne examines the Administrative Appeals Tribunal's decision in a case involving Roche Products, saying the preliminary ruling represents the first judicial review of a substantive transfer pricing issue in Australia. Analysis, Page 38

Secondary Adjustments, Repatriation in Transfer Pricing Cases

Patricia Lewis and John Breen of Caplin & Drysdale in Washington, D.C., discuss the rationality of secondary adjustments under U.S. rules. ... The IRS issues a directive on conforming adjustments in the case of Section 965 repatriations. Perspective, Page 28; Page 7; Text, Page 23