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

Transfer Pricing Highlights

Volume 17 Number 12
Wednesday, October 23, 2008

Anticipated Disclosure in Financial Industry Seen Presenting Opportunities
Calls for increased regulation and government scrutiny of the financial sector could mean more transfer pricing information will be available for financial services companies, a practitioner says as he and others discuss transfer pricing and risk management in the industry.

Practitioners Assess Transfer Pricing Landscape in Brazil
Transfer pricing practitioners lay out the numerous challenges of operating in Brazil even as the country's tax department announces a relaxation of the rules covering company challenges to profit margins set by the government. Meanwhile, treaty negotiations between Brazil and the United States are reportedly at a standstill.

September FIN 48 Filers Include Taxpayers From Luxembourg, Japan
Multinational companies headquartered in Hong Kong, Japan, Luxembourg, and the Netherlands report transfer pricing disputes in their September filings with the U.S. Securities and Exchange Commission, while U.S.-based Synopsys Inc. says it reached a settlement with the Internal Revenue Service on adjustments involving 2000-01.

China Sets 5:1 Debt-Equity Ratio for Financial Institutions, 2:1 for Others
China for the first time establishes thin capitalization debt-equity ratios of 5:1 for financial institutions and 2:1 for other institutions, but permits companies to deduct interest outside these ratios if documentation shows related-party financing was at arm's length.