Featured News

Bulgaria

Bulgarian mandatory transfer pricing documentation rules enacted

August 23, 2019

Ekaterina Aleksova, Senior Manager at PricewaterhouseCoopers Bulgaria discusses a new law introducing mandatory transfer pricing documentation in Bulgaria which was officially published in early August . . .

CIAT

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

August 20, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss a recent Inter-American Center of Tax Administrations (CIAT) transfer pricing publication which proposes two measures for clarifying the application of the best method rule and thereby preventing the overuse of the transactional net margin method. . .

Americas

US Senate ratifies protocols to tax treaties with Japan, Switzerland, Luxembourg

July 17, 2019

The US Senate today ratified protocols to the US’s tax treaties with Japan, Switzerland, and Luxembourg. This follows the Senate ratification on . . .

Americas

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

August 17, 2019

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary to . . .

Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

Americas

Chile government introduces significant changes to tax reform package

July 10, 2019

Francisco Sepúlveda of RGS Abogados, Santiago de Chile, analyzes the latest changes to Chile’s comprehensive tax reform package, which include further regulation regarding digital services, new profit distribution rules, and a new definition of taxable expense . . .

Transfer pricing planning for oil refining, paper and pulp, and other continuous process industries

July 26, 2019

Gaurav Jain and Priya Mani Bhutani discuss transfer pricing issues associated with continuous process industries . . .

Australia

Australian tax office addresses transfer pricing, debt-equity rule interaction

July 10, 2019

The Australian Tax Office on 4 June released guidance which deals with the interaction between the transfer pricing rules and the debt-equity rules, write Leslie Prescott-Haar & Stefan Sunde, TP EQuilibrium | AustralAsia LP . . .

Americas

IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangements

August 5, 2019

The US IRS will once again examine allocations between group members of employee . . .

Americas

US to retaliate against France in response to digital tax, Trump says

July 26, 2019

President Donald Trump today announced in a tweet that the US will retaliate. . .

Americas

Brazil’s effort to align its transfer pricing rules with OECD standards

July 17, 2019

Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the status of a joint effort of the OECD and Brazil’s tax authority to reduce the gaps between Brazil’s transfer pricing regime and the OECD transfer pricing guidelines ahead of Brazil’s ascension to the OECD . . .

CIAT

CIAT releases detailed proposals aimed at stopping transfer pricing abuse

July 17, 2019

The Inter-American Center of Tax Administrations (CIAT) on July 15 released comprehensive and detailed proposals aimed at preventing abusive transfer pricing, write Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium . . .

Digital Economy

First look: UK Finance Bill draft legislation includes details on new digital services tax

July 11, 2019

Draft legislation and supporting documents for UK Finance Bill 2019–2020, the vehicle . . .

Asia-Pacific

India Budget 2019: key international tax and transfer pricing developments

July 7, 2019

Mukesh Butani and Shreyash Shah of BMR Legal Advocates discuss India Budget 2019 which includes a few proposals that will have a material impact on cross-border taxation and transfer pricing . . .

Europe

The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?

August 2, 2019

Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting project has increased the scope for differences of opinion between tax authorities of different countries, writes Danny Beeton of Arendt & Medernach, Luxembourg . . .

Europe

Absolut wins Swedish transfer pricing dispute over application of benchmarking study and multiple year analysis

July 7, 2019

Madeleine Thörning and Erik Koponen of Thorning Koponen Consulting analyze a Sweden Supreme Administrative Court decision in a transfer pricing dispute between Swedish subsidiary, Absolut Company AB, and the Swedish Tax Agency . . .

Europe

Poland provides guidance on transfer pricing comparability for multinationals

June 25, 2019

Dr. Monika Laskowska, a partner with PwC Poland, discusses the Polish Ministry of Finance’s June 19 explanatory note addressing transfer pricing comparability analyses . . .

Asia-Pacific

Israeli tax authorities issue updated transfer pricing declaration Form 1385

August 12, 2019

The Israeli tax authorities recently issued an updated Form 1385, which is a declaration regarding intercompany transactions with related parties, write Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher JH Consulting Ltd . . .

Americas

US Senate ratifies long-pending tax treaty protocol with Spain

July 17, 2019

The US Senate on July 16 ratified a protocol to the US-Spain tax treaty (Treaty Doc. 113-4), the first US ratification of a tax treaty or tax treaty protocol since 2010. The protocol . . .

Africa

South Africa proposes more refinements to anti-dividend stripping rules

June 20, 2019

Emil Brincker of Cliffe Dekker Hofmeyr Inc. discusses South Africa draft legislation released June 10 that is designed to further strengthen the recently introduced anti-dividend stripping rules . . .

Asia-Pacific

Hong Kong provides guidance on transfer pricing rules and documentation requirements

July 29, 2019

Agnes Lo, Associate Professor, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss guidance issued by the Hong Kong Inland Revenue Department July 18 setting out the IRD’s views on transfer pricing, permanent establishment, and the foreign tax deduction. . . .

Europe

Spanish appeals court rules on IKEA subsidiary’s approach to transfer pricing comparability, arm’s length range

June 24, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss the Spanish Court of Appeal’s decision earlier this year in IKEA, a transfer pricing case addressing the taxpayer’s application of the transactional net margin method (TNMM) . . .

Digital Economy

On turnover-based taxes and digital taxes: the EU Advocate General’s opinion in Vodafone

June 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses an EU Advocate General’s opinion issued June 13 addressing Vodafone’s challenge to the Hungarian telecommunication tax . . .

Asia-Pacific

Turkey proposes another tax amnesty for repatriation of foreign assets

July 17, 2019

Ramazan Biçer of Centrum Turkey discusses the Turkish government’s latest tax amnesty, proposed on July 8, which applies to the repatriation of foreign assets . . .

Americas

US announces probe into France’s digital services tax

July 10, 2019

The US will investigate whether France’s digital services tax, expected to pass the Senate . . .

Europe

Netherlands draft tax law targeting hybrid mismatches includes new documentation requirement

July 7, 2019

Mehdi el Manouzi and Michiel Moison of PwC Netherlands discuss the Dutch government’s July 2 legislative proposal implementing the EU rules targeting hybrid mismatches . . .

Europe

UK tribunal reverses controversial decision on Jersey companies’ tax residency under central management and control test

June 13, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss an important UK tribunal decision addressing the central management and control test for tax residency . . .

Africa

Switzerland’s Federal Council approves plan to exchange account data with 19 more country tax administration

May 30, 2019

Davide Anghileri of the University of Lausanne writes that Switzerland’s Federal Council adopted a dispatch yesterday approving the introduction of automatic exchange of financial account information with 19 more countries . . .

Austria

EU loss in Polish State aid case may be a win for digital services tax

May 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses a May 16 EU General Court decision in Poland v. Commission which could have implications for the legality, under EU State aid rules, of unilateral European digital services tax measures . . . .

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

G20 leaders approve digital work plan to address taxation of multinational groups

July 1, 2019

G20 leaders, at their summit in Osaka, Japan on June 28–29 endorsed a work plan developed by. . .

Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

Americas

Newly signed Brazil-Uruguay tax treaty will force companies to review structures

June 13, 2019

Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados discusses the new Brazil–Uruguay tax treaty and protocol, signed June 7 . . .

Europe

Italy clarifies interaction of patent box regime and foreign tax credit

June 10, 2019

Davide Anghileri of the University of Lausanne discusses clarifications made by the Italian revenue agency on May 28 concerning the interaction of the Italian patent box regime the foreign tax credit. . .

Americas

US urging market countries to accept only modest changes to international tax system

June 6, 2019

The US is urging countries to agree to new international tax rules that would allocate a limited amount of additional profit and related taxing rights to countries where a multinational’s customers or digital users reside. In exchange for these additional taxing . . .

American Samoa

EU Council revises tax blacklist, plans less frequent list updates

May 17, 2019

Davide Anghileri of the University of Lausanne discusses today’s decisions by the EU Council regarding the EU list of non-cooperative tax jurisdictions . . .

Asia-Pacific

Amended India-China tax treaty protocol enters into force

July 19, 2019

An amending protocol to the China-India tax treaty has entered into force according to a July 17 notice of the Indian government, writes Prabhakar KS of Shree Tax Chambers . . .

Europe

UK Finance Bill 2019-20: what international businesses need to know

July 17, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss selected provisions in draft legislation and explanatory notes to the UK Finance Bill 2019-20 published on July 11 including the UK’s proposed digital services tax . . .

Europe

EU court addresses legality of progressive turnover taxes

June 30, 2019

Dr. Patricia Lampreave, a professor at the Instituto de Estudios Busatiles, Madrid discusses a June 27 EU General Court opinion annulling an EU Commission decision on the compatibility of the Hungarian advertisement tax with the EU State aid rules . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

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