FSTP Perspectives - Archive

A publication for financial services industry tax and transfer pricing professionals.

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.

Previous Issues

April 2009

In this publication you can read:

  • Our Foreword prepared by Aamer Rafiq, PwC UK Financial Services Transfer Pricing Leader;
  • Comment & Analysis: ‘From my Perspective’ prepared by Jobst Wilmanns;
  • Tax controversy and intra-group financial transactions–an emerging battleground in challenging financial times, Jeff Rogers, Michel van der Breggen & Bill Yohana;
  • UK Tax Court finds for HMRC in UK Transfer Pricing Case: Lisa Casley, Aamer Rafiq, Annie Devoy & Iain Sinclair;
  • Recent transfer pricing developments in Singapore: Paul Lau;
  • Update on proposed UK ‘debt cap’: Andrew Paton, Lirize Loots;
  • Recent developments that affect transfer pricing in Korea: Shin-Jong Kang;
  • Country Focus: Argentina prepared by Jose Maria Segura
January 2009

In this publication you can read:

  • Our Foreword, Peter Yu and David McDonald
  • Comment & Analysis: ‘From my Perspective’, Lindy Paull
  • OECD releases discussion draft on the TP aspects of business restructuring, Ian Dykes
  • Post deal integration - a Transfer Pricing challenge, David McDonald and Shyamala Vyravipillai
  • Brazil: expanded definition of low tax jurisdictions, Alvaro Taiar, Mac Calva and Rita Tavares de Pina
  • OECD: New article 7, Junko Yamato and Rita Tavares de Pina
  • Netherlands: Dutch supreme court applies the arm's length principles to loans, Arnout van der Rest, Marc Diepstraten, Hugo Vollebregt and Michel van der Breggen
  • The argument for Transfer Pricing documentation in the Japanese environment, Ryann Thomas
  • Sweden: Intercompany interest case settled in the administrative court of appeal, Pär Magnus Wiséen and Magnus Griven
  • Country Focus: Singapore, Paul Lau
  • Country Focus: Malaysia, Jagdev Singh and Lilia Adlina Azmi
July 2008

In this publication read about:

  • Our Foreword prepared by Adam Katz - Adam revisits the highlights and Hot Topics that arose from the recent round of Master Series events;
  • Comment & Analysis: ‘From my Perspective’ prepared by Stuart Porter, PwC Japan's FSTP Leader;
  • The emerging market for Carbon Emissions; a general article on the growth of this market, first in the EU and now in the US;
  • TP Developments in the Philippines; Carlos Carado discusses a recent government memorandum outlining the transfer pricing of debt in the country;
  • US Broadens APA programme: Richard Barrett et al discuss the inclusion of PEs into the US' expanding APA programme; and
  • Country Focus: Netherlands, prepared by the FSTP Leadership in Rotterdam and Amsterdam, Hugo Vollebrecht and Michel van der Breggen.
February 2008

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.





December 2007 / January 2008

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.
October/November 2007

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
August 2007


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
June 2007


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.






April 2007

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