Transfer pricing briefing for September 2013

The US has confirmed changes to the cost sharing rules. The IRS faces a protective order from Amazon to limit information requests on audit. Indian proposals on Safe Harbours are announced, whilst the Mumbai tribunal rules on the force of attraction principle for permanent establishments. Vietnam issues draft APA regulations. Brazil adds further guidance on allowable loan interest. Australia beefs up its transfer pricing enforcement with new rules giving powers to recharacterise transactions and an upfront documentation regime to limit possible penalties.