Index
Advance pricing agreements/arrangements (APAs)
Australia
Canada
China
India
Indonesia
Japan
Malaysia
New Zealand
Singapore
South Korea
Sri Lanka
Taiwan
Vietnam
Allocation keys
Australia
based on marketing costs
based on R&D costs
China-Taiwan trade
functional analysis
Hong Kong
importance of
Malaysia-Singapore real estate leasing example
OECD guidelines
Singapore
Arm’s length principle
Australia
China
cost pooling contracts
Hong Kong
Japan
Malaysia
New Zealand
OECD guidelines
PATA Transfer Pricing Documentation Package
Philippines
Singapore
South Korea
Sri Lanka
Taiwan
Thailand
Vietnam
ASEAN (Association of Southeast Asian Nations)
ASEAN + three
Associated enterprises
Australia
China
Hong Kong
India
Malaysia
New Zealand
PATA Documentation Package
Philippines
Singapore
South Korea
Sri Lanka
Thailand
transactional profit split method
Association for Relations Across the Taiwan Straits (ARATS)
Association of Southeast Asian Nations (ASEAN)
Australia
advance pricing arrangement (APA) program
allocation keys
arm’s length principle
associated enterprises
audits
benchmarking analysis
comparability analysis
comparable uncontrolled price method (CUP)
cost method
cost plus method
decision tree
documentation
double tax agreements (DTAs)
functional analysis
Income Tax Assessment Act of 1936 (ITAA)
intangible property
marketing activities
and New Zealand transfer pricing guidelines
OECD membership
overview
PATA membership
penalties
permanent establishment of dependent agent
pricing information, sources and availability of
pricing methods
profit split methods
reasonable balance criterion
related parties and related party transactions
resale price method
reviews of transfer pricing
Schedule 25A
scoring
small to medium business threshold
small to medium businesses, risk assessment approach for
testing transfer prices, steps for
transactional net margin method
transactional net margin method (TNMM)
watch list
Berry method
Bilateral investment treaties (BITs)
Canada
advance pricing agreements (APAs)
common law
controlled foreign corporations
ICSID Convention
India, treaties with
PATA membership
permanent establishment issues
China
administration of transfer pricing
advance pricing arrangements (APAs)
allocation keys, China-Taiwan trade
Annual Report of Enterprise Overseas Investment
annual reporting
anti-avoidance
arbitration
arm’s length principle
associated enterprises
audits
CFC Chinese Resident Shareholder Identity Confirmation Notice
Chinese language
comparability analysis
comparable uncontrolled price method (CUP)
compensating adjustments
compliance failures
confidentiality
controlled foreign corporations (CFCs)
corresponding adjustments
cost plus method
cost sharing agreements (CSAs)
debt to equity ratio
desktop audits
documentation
double taxation
effective date of regulations
Enterprise Income Tax Law (EIT)
equity investment
exemption for domestic Chinese enterprises
exemptions from contemporaneous documentation
extensions of time
field office audits
follow-up supervision
functional analysis
general profit split method
holidays, treatment of
intangible property
interest charge
interest expenses
international negotiations
loans to and from related parties
material processing
mergers and divisions
mutual agreement procedure (MAP)
Notice of Special Tax Audit Conclusion
Notice of Tax Audit
offsets
overview
pricing adjustments
pricing methods
profit split method
reasonable adjustments
regulations by chapter
related party debt to equity
related party reporting
related party transactions
resale price method
research and development (R&D) activities
residual profit split method
retention of documents
services transfer pricing
signatures and seal
special adjustments
Special Tax Audit Adjustment Notice
supplementary provisions
Taiwan, trade with
tax, payment of
tax authorities, powers of
Tax Collection and Administration Law
tax returns
tax treaties and arrangements
thin capitalization
transactional net margin method (TNMM)
transfer pricing procedures
Comparability analysis
Australia
China
Hong Kong
Malaysia
PATA Transfer Pricing Documentation Package
Singapore
Sri Lanka
Comparable profit split method (Japan)
Comparable profits method
Indonesia
New Zealand
Taiwan
Vietnam
Comparable uncontrolled price method (CUP)
Australia
China
Hong Kong
India
Indonesia
Japan
Malaysia
New Zealand
Singapore
South Korea
Sri Lanka
Taiwan
Thailand
United States
Vietnam
Contribution analysis
Malaysia
New Zealand
Singapore
Contribution profit split method (Japan)
Convention on the Settlement of Investment Disputes Between States and Nationals of Other States
Cost contribution agreements/arrangements (CCAs). See also Cost sharing agreements (CSAs)
Japan
Malaysia
New Zealand
PATA Transfer Pricing Documentation Package
Singapore. See also Cost pooling
South Korea
Cost plus method
Australia
China
Hong Kong
India
Indonesia
Japan
Malaysia
New Zealand
Philippines
Singapore
South Korea
Sri Lanka
Taiwan
Thailand
Vietnam
Cost plus method, methods equivalent to methods consistent with (Japan)
Cost pooling (Singapore)
Cost sharing agreements (CSAs). See also Cost contribution agreements/arrangements (CCAs)
China
India
and shared service arrangements (SSAs)
Singapore
South Korea
United States
Cross-Straits Economic Cooperation Framework Agreement (ECFA)
Debt to equity ratio. See also Thin capitalization rules
Documentation
Australia
China
Hong Kong
India
Indonesia
Japan
Malaysia
New Zealand
PATA, Transfer Pricing Documentation Package
Philippines
shared service arrangements (SSAs)
Singapore
South Korea
Sri Lanka
Taiwan
Thailand
United States
Vietnam
Double tax agreements (DTAs)
Australia
Hong Kong
India
New Zealand
Thailand
Double taxation
China
Hong Kong
India
Malaysia
permanent establishment issues
Singapore
Earning stripping. See Thin capitalization rules
Economic crisis of 2008–2010
Engineering activities
General profit split method (China)
Gift tax (South Korea)
Hong Kong
abusive tax schemes. See also Ngai Lik litigation
advance ruling process
advance rulings
allocation keys
anti-avoidance. See also Ngai Lik litigation
appropriate adjustments
arm’s length principle
associated enterprises
audits
business strategies
comparability analysis
comparable uncontrolled price method (CUP)
contract terms
cost plus method
direct charges for intragroup services
documentation
double tax agreements (DTAs)
double taxation
economic and marketing circumstances
financial services
functional analysis
global price lists
indirect charges for intragroup services
Inland Revenue Ordinance
intangible property
international business companies
intragroup services
loans, intercompany
marketing activities
mutual agreement procedure (MAP)
Ngai Lik litigation
“objective commercial explanation” standard
and OECD Transfer Pricing Guidelines
overview
permanent establishment issues
pricing methods
profit split method
profits and income, sources of
profits transferred to international business company, assessment of
reinvoicing schemes
related party services
reliability of data
resale price method
shareholder activities and stewardship functions
Singapore services transfer pricing compared
tax avoidance versus tax evasion
transactional net margin method (TNMM)
Transfer Pricing Guidelines
ICSID. See International Centre for Settlement of Investment Disputes (ICSID)
India
accountant’s report
administration of transfer pricing
advance pricing agreements (APAs)
affiliated enterprises
appeals
associated enterprises
audits
Authority for Advance Ruling (AAR)
background
burden of proof
comparable uncontrolled price method (CUP)
Competent Authority Agreement (2002)
cost plus method
cost sharing
documentation
double tax agreements (DTAs)
double taxation
intangible property
litigation
loans, to and from related parties
most appropriate method (MAM)
and OECD guidelines
penalties
permanent establishment issues
pricing methods
profit split methods
related parties
resale price method
research and development (R&D) activities
small businesses
tax holidays
tax treaties
transactional net margin method (TNMM)
travel services
Indonesia
International Centre for Settlement of Investment Disputes (ICSID)
Intragroup services. See also Services transfer pricing
Hong Kong
Japan
Malaysia
OECD guidelines
Singapore
South Korea
Japan
Act on Special Measures Concerning Taxation (ASMT)
adjustments for differences
advance pricing arrangements (APAs)
arm’s length principle
audits
background
basic policies
bilateral investment treaty with South Korea
commercial value of services
comparable profit split method
comparable uncontrolled price method (CUP)
compensating adjustments
complexity of transfer pricing regulations
consolidated groups
and consumption tax
contribution profit split method
cost contribution arrangements (CCAs)
cost plus method
distribution channels
documentation
“equivalent to” methods
estimation method
examinations
foreign transferred income
functional analysis
human resource business activities
intangible property
intragroup services
Japanese language
loans, intercompany
loans of employees
marketing activities
methods consistent with comparable uncontrolled price method
methods equivalent to methods consistent with cost plus method
multiple-year considerations
mutual agreement procedure (MAP)
National Tax Agency (NTA)
OECD guidelines, reliance on
OECD membership
PATA membership
pricing methods
profit split methods
quality control know-how
Reference Case Studies on the Application of Transfer Pricing Taxation
regulations (Commissioner’s Directive on the Operation of Transfer Pricing)
resale price method
research and development (R&D) activities
residual profit split method
selection of pricing method
services
services transfer pricing
target profit margin
tax returns
thin capitalization
transactional net margin method (TNMM)
Transfer Pricing Administrative Guidelines
and withholding tax
Korea. See South Korea
Litigation
India
Morgan Stanley
Ngai Lik litigation
Toyota case
Loans, to and from related parties. See also Related parties and related party transactions
China
Hong Kong
India
Japan
Singapore
Thailand
Malaysia
advance pricing agreements (APAs)
advance ruling guidelines
allocation keys
arm’s length principle
associated enterprises
audits
comparability analysis
comparable uncontrolled price method (CUP)
contribution analysis
cost contribution agreements/arrangements (CCAs)
cost plus method
distribution channels
documentation
double taxation
functional analysis
Income Tax Act 1967
intangible property
intragroup services
Malaysia-Singapore real estate leasing example
marketing activities
OECD guidelines, reliance on
overview
penalties
pricing methods
procedure
profit split methods
resale price method
research and development (R&D) activities
residual profit split method
retention of documents
services transfer pricing
tax treaties
transactional net margin method (TNMM)
Transfer Pricing Guidelines
Marketing activities
allocation keys based on marketing costs
Australia
Hong Kong
Japan
Malaysia
New Zealand
Singapore
Model Tax Treaty (OECD)
Model tax treaty (United Nations)
Most appropriate method (MAM) (India)
Most favored nation provisions
Most reasonable method (South Korea)
Mutual agreement procedure (MAP)
China
Hong Kong
Japan
OECD guidelines
Singapore
South Korea
New Zealand
advance pricing agreements (APAs)
arm’s length principle
associated enterprises
audits
Australian and U.S. pricing guidelines, reliance on
burden of proof
comparable profits method
comparable uncontrolled price method (CUP)
contribution analysis
corresponding adjustments
cost contribution agreements/arrangements (CCAs)
cost plus method
documentation
double tax agreements (DTAs)
functional analysis
intangible property
market penetration strategy
marketing activities
OECD guidelines, reliance on
OECD membership
overview
penalties
pricing methods
profit split method
resale price method
residual profit split analysis
risk to the revenue
tax treaties
transactional net margin method (TNMM)
Ngai Lik litigation
OECD. See Organisation for Economic Co-operation and Development (OECD)
Organisation for Economic Co-operation and Development (OECD)
formation of
members of
Model Tax Treaty
Transfer Pricing Guidelines. See Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD)
transfer pricing rule
Pacific Association of Tax Administrators (PATA)
PATA Transfer Pricing Documentation Package
People’s Republic of China (PRC). See China
Permanent establishment issues
agency relationships
Australia
Canada
common law criteria
consequences of permanent establishment status
declining businesses
direct business activities
double taxation
entirety of operations
exemptions for preparatory and auxiliary activities
functional analysis
Hong Kong
India
more-than-stewardship activities
OECD approach
overview
personnel shifts from parent to subsidiary
Singapore
South Korea
and tax treaties
time thresholds
and transfer pricing
United States
Philippines
Price lists
Pricing methods. See specific methods
Profit split methods. See also Residual profit split method
Australia
China
Hong Kong
India
Japan
New Zealand
OECD
Philippines
Singapore
South Korea
Sri Lanka
Taiwan
Thailand
transactional profit split method
Vietnam
Quality control know-how (Japan)
Reference Case Studies on the Application of Transfer Pricing Taxation (Japan)
Reinvoicing arrangements
Related parties and related party transactions. See also Arm’s length principle
Australia
China
Hong Kong
India
Indonesia
Japan. See also Reference Case Studies on the Application of Transfer Pricing Taxation (Japan)
OECD guidelines
Singapore
South Korea
Sri Lanka
Taiwan
Thailand
Vietnam
Republic of China (ROC). See Taiwan
Resale minus method (South Korea)
Resale price method
Australia
China
Hong Kong
India
Indonesia
Japan
Malaysia
New Zealand
Singapore
Sri Lanka
Taiwan
Thailand
Vietnam
Research and development (R&D) activities
allocation keys based on R&D costs
China
India
Japan
Malaysia
Taiwan
transactional profit split method
Residual profit analysis (Australia)
Residual profit split analysis
Japan
New Zealand
Residual profit split method
China
Japan
Malaysia
Philippines
Singapore
Sri Lanka
Risk analysis
Services cost method (SCM)
Services transfer pricing. See also Cost pooling; Shared service arrangements (SSAs)
China
Hong Kong
Japan
Malaysia
OECD guidelines
PATA Documentation Package
Singapore
South Korea
specialized services
Sri Lanka
subsidiary services
Taiwan
Thailand
Vietnam
Shared service arrangements (SSAs)
and cost sharing agreements (CSAs)
documentation
intangible property
Singapore (cost pooling)
United States
Singapore
advance pricing arrangements (APAs)
allocation keys
arm’s length principle
associated enterprises
audits
burden of proof
comparability analysis
comparable uncontrolled price method (CUP)
contribution analysis
cost contribution arrangements (CCAs)
cost plus method
cost pooling
cost sharing
direct and indirect charge methods for services
documentation
double taxation
economic or commercial benefit standard
five percent markup for routine services
functions, comparison of
Hong Kong services transfer pricing compared
independent commercial prices
intangible property
intragroup services
judgment, use of
loans, to and from related parties
marketing activities
mutual agreement procedures (MAPs)
OECD guidelines
penalties
permanent establishment issues
pricing analysis
pricing methods
profit split methods
reasonable balance criterion
related parties and related party transactions
related party loans
resale price method
residual profit split method
services
strict cost pass-through
tax treaties
transactional net margin method (TNMM)
Transfer Pricing Consultation
Transfer Pricing Guidelines
Transfer Pricing Guidelines for Related Party Loans and Related Party Services
transfer pricing questionnaire
Small and medium businesses
Australia. See Australia
India, transfer pricing exemptions for small businesses
South Korea
advance pricing agreements (APAs)
arm’s length principle
associated enterprises
audits
Berry method
bilateral investment treaty with Japan
burden of proof
comparable uncontrolled price method (CUP)
competent authority relief
corresponding adjustments
cost contribution agreements
cost plus method
cost sharing agreements
debt to equity ratio
direct ownership
documentation
economic interest and control
gift tax
indirect ownership
information requests
intangible property
intragroup services
most reasonable method standard for pricing
mutual agreement procedure (MAP)
National Tax Service (NTS)
OECD membership
overpayments
overview
penalties
permanent establishment
pricing methods
profit split method
related parties and related party transactions
resale minus method
special relationships
substance over form
tax haven rules
tax payments
tax treaties
thin capitalization rules
transactional net margin method (TNMM)
underpayments
Sri Lanka
advance pricing agreements (APAs)
arm’s length principle
associated enterprises
associated undertakings (test of control)
burden of proof
comparability analysis
comparable uncontrolled price method (CUP)
cost plus method
de minimus threshold for transfer pricing
documentation
intangible property
overview
pricing methods
profit split method
related parties and related party transactions
resale price method
residual profit split method
services transfer pricing
transactional net margin method (TNMM)
Straits Exchange Foundation (SEF)
Taiwan
advance pricing arrangements (APAs)
arm’s length principle
Association for Relations Across the Taiwan Straits (ARATS)
audits
China, trade with
comparable profits method
comparable uncontrolled price method (CUP)
cost plus method
documentation
functional analysis
intangible property
penalties
pricing methods
profit split methods
related parties and related party transactions
resale price method
research and development (R&D) activities
services transfer pricing
transfer pricing
uncontrolled transaction method
Tax evasion
Tax haven rules (South Korea)
Tax holidays
India
Vietnam
Tax treaties
Canada
China
India
Japan
Malaysia
New Zealand
permanent establishment issues. See also Permanent establishment issues
Singapore
South Korea
treaty shopping limitations
United Nations model tax treaty
United States
Thailand
arm’s length principle
associated enterprises
audits
burden of proof
comparable uncontrolled price method (CUP)
cost plus method
documentation
double tax agreements (DTAs)
intangible property
loans to and from related parties
pricing methods
profit split methods
related parties and related party transactions
resale price method
services transfer pricing
transactional net margin method (TNMM)
transfer pricing
Thin capitalization rules
China
Japan
South Korea
Transactional net margin method (TNMM)
Australia
China
Hong Kong
India
Japan
New Zealand
Singapore
South Korea
Sri Lanka
Thailand
United States
Transactional profit split method
Transfer Pricing Documentation Package
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD)
allocation keys
arm’s length principle
China
Hong Kong
India
intangible property
intragroup services
Japan
Malaysia
mutual agreement procedure (MAP)
New Zealand
and PATA Documentation Package
permanent establishment provisions
Philippines
pricing methods
profit split methods
related party services
revisions
shareholder activities
Singapore
specialized services
Taiwan
United States
Transfer pricing schemes. See also Reinvoicing arrangements
TransferPricingConsortium.com
Uncontrolled transaction method (Taiwan)
United Nations
Commission on International Trade Law (UNCITRAL)
model tax treaty
United States
advanced pricing agreements
“best method” rule
bilateral APA with Australia
bilateral investment treaties (BITs)
comparable uncontrolled price method using in-house comparable
controlled foreign corporation rules
cost sharing agreements
documentation
and formation of OECD
intangible property
intellectual property
interquartile range for pricing
and New Zealand transfer pricing guidelines
and OECD guidelines
PATA membership
penalties
permanent establishment issues
shared service arrangements (SSAs)
Tax Equity and Fiscal Responsibility Act of 1982, section 482 documentation rules
tax jurisdiction
tax treaties
Toyota case
transactional net margin method (TNMM)
transfer pricing guidelines
Vietnam
abusive tax schemes
advance pricing agreements (APAs)
arm’s length principle
audits
comparable profits method
comparable uncontrolled price method (CUP)
control
cost plus method
documentation
intangible property
penalties
pricing methods
profit split methods
related parties and related party transactions
resale price method
services transfer pricing
tax holidays
transfer pricing
World Bank Group
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