FSTP Perspectives

FSTP Perspectives is a publication focusing solely on transfer pricing and related issues for financial institutions.It offers an insight into trends and developments, tax authorities’ approaches, and “hot” topic issues in financial services transfer pricing.

In this publication, read about:

• Our Foreword by Isabel Verlinden, PwC Eurofirms Transfer Pricing Leader;
• Reinsurance - a transfer pricing hot topic;
• Transfer pricing implications on the new German-US tax treaty;
• HMRC's new approach to transfer pricing work ; and
• A Country Focus on China.

In this publication, read about:

• Our Foreword by Adam, Annie and Aamer, leaders of the PwC Financial Services Transfer Pricing Practice;
• Developments arising from the consultation meeting held in Paris on 26 November on the latest discussion draft of the OECD Paper IV on Insurance;
• Summary of the Treasury Report to US Congress issued on 26 November which addressed income stripping and transfer pricing regulatory gaps;
• Overview of the Draft Taxation Determination issued by the ATO on 28 November, which provides guidance to taxpayers regarding how Australia's thin capitalisation provisions interact with the transfer pricing provisions and the business profits article and associated enterprises article of double tax treaties; and
• Country Focus: an overview of the financial services transfer pricing environment in Spain.

In the Oct/Nov issue, read about:

• Our foreword by John Masters, leader of PwC financial services tax in Asia Pacific
• The new VAT rules in Ireland which include transfer pricing provisions
• The re-proposed U.S. Global Dealing Regulations which are to be similar to the 1998 Regulations
• What is currently happening with business restructuring in Australia
• Country Focus: an overview of the financial services transfer pricing environment in Canada
• Recent articles: Ruling in the case of creation of PE and allocation of income in India
• A blog from Peter Brewin, a secondee in the PwC Tokyo office, on what life is like working in Japan
• An update of upcoming events taking place around the PwC FSTP global network

In the August issue, read about:

• The increased transfer pricing audit activity in Denmark and how this may impact companies operating within the financial services industry
• The recent international tax conference held in New Delhi, India which focused on the continual efforts to rationalise India's tax system
• A summary of the proposed changes to the Russian transfer pricing legislation which are set out in the draft bill issued by the Russian Ministry of Finance in February 2007
• The landmark ruling by the Supreme Court of India issued on 9 July 2007 in respect of whether Morgan Stanley had a PE in India by virtue of the back office operations outsourced in India
• Country Focus: An overview of the financial services transfer pricing environment in Australia
• A summary of recently published articles written by PwC financial services tax and transfer pricing practitioners

In this issue, you will read about the developments in financial services transfer pricing around the world, including the increased focus by tax authorities around the world on intra-group loans by non-financial corporations, the recent OECD council resolution which invited Chile, Estonia, Israel, Russia and Slovenia to OECD membership talks and offered enhanced engagement with a view to possible membership to Brazil, China, India, Indonesia and South Africa, as well as an update on the transfer pricing regime in India which has now been in place for six years.

In the April issue, read about:

• A personal insight into the very topical area of the OECD's project on the attribution of profits to permanent establishments by Richard Collier, PwC Banking & Capital Markets Tax Leader
• An exploration of the key transfer pricing issues arising for hedge funds, and in particular the distribution/capital raising aspect of their businesses
• The acceptance of the "functionally separate entity" approach for the attribution of profits to permanent establishments by Germany
• Changes to Her Majesty's Revenue and Custom's guidance on the United Kingdom thin capitalisation rules
• The expected changes in transfer pricing legislation for Germany in 2008
• An update on the US Global Dealing Regulations
• Developments with respect to the transfer pricing issues in the private equity market in the United Kingdom
• An update on the Japanese transfer pricing guidelines
• How financial services transfer pricing is becoming more of a hot topic in Italy and the areas that the Italian tax authorities have been focusing on in their tax audits
• Future events to be hosted by PwC offices including Germany, and our global Masters Series events in London, Toronto, Sydney and Hong Kong