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

Transfer Pricing Highlights

Volume 18 Number 12
Wednesday, November 5, 2009

Japan MAP Cases Reach Record, 90 Percent Concern Transfer Pricing

Mutual agreement procedure negotiation requests to settle tax disputes filed with Japan's National Tax Administration reach a record high of 174, with 90 percent of the cases concerning transfer pricing. The number of advance pricing agreement requests reach a high of 130 as well, the NTA said in its APA/MAP report for tax year 2008.

Accounting Group Asks OECD to Revise Transfer Pricing Guidance

The Organization for Economic Cooperation and Development should revise its transfer pricing documentation requirements to make them less onerous and time consuming, a policy paper by the global Association of Chartered Certified Accountants says.

IRS Appeals to Handle Penalties on Preassessment Basis

The Internal Revenue Service is working to handle penalty issues on a preassessment basis for international taxpayers, IRS Appeals Chief Diane Ryan says.

Initiate MAP to Avoid Cascade of Corresponding Adjustments, Officials Say

Tax officials from the Organization for Economic Cooperation and Development, Germany, the Netherlands, and Norway say a taxpayer's only realistic solution to prevent a cascade of corresponding adjustments when faced with a transfer pricing adjustment imposed by one country is to commence a mutual agreement procedure case under the relevant tax treaty.