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

Transfer Pricing Highlights

Volume 18 Number 13
Wednesday, November 19, 2009

Aggressive PE Enforcement at Odds with Indian Reform Goals

While India's recent international tax reform efforts seek to provide more certainty and boost foreign investment, a look at the jurisprudence surrounding the issue of permanent establishment shows the government's aggressive stance may be incompatible with its goals. ... Recently enacted transfer pricing reforms have met some stumbling blocks, resulting in the postponement of safe harbor rules and of establishing an alternative dispute board to approve transfer pricing assessments before issuance.

October Transfer Pricing Disclosures Include Avon's Dispute with Brazil

Taxpayers making FIN 48 disclosures detailing transfer pricing issues with the Securities and Exchange Commission in October included global beauty firm Avon Products Inc., which detailed transfer pricing assessments by Brazil's taxing authority in determining excise taxes. See the alphabetical listing of companies disclosing transfer pricing issues and excerpts from those SEC filings that contain FIN 48 transfer pricing disclosures and excerpts.

Recession Can Undermine Centralized Supply Chain Advantage, KPMG Says

The continuing global economic downturn may force multinational corporations to adjust centralized supply chain operations because recessions in some countries inadvertently are increasing the multinational enterprise's overall effective tax rates, according to a KPMG report.