Davide Anghileri of the University of Lausanne discusses an Italian law adopted April 24 that modifies Italy's transfer pricing provisions to make them in-line with the OECD’s arm’s length principle, adds corresponding adjustments to Italian tax law, and updates the list of intellectual property that can qualify for the patent box regime . . .
The United Arab Emirates on April 21 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 109th jurisdiction to participate in the convention. The treaty, developed in 1988 by the OECD and the Council of Europe, would enable . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses a Trump administration executive order, issued last Friday, mandating the review of tax regulations, noting that those hoping the order will lead to the repeal of US earnings stripping and/or inversion tax regulations may wind up disappointed . . . .
Australia’s Full Federal Court today dismissed Chevron's appeal in a transfer pricing case involving intercompany loans, handing the Australian Taxation Office (ATO) a key victory. By unanimous judgment, the full bench . . .
Yoshio Uehara, César De la Parra, and Ignacio Mosquera of Chevez, Ruiz, Zamarripa, analyze final rules, issued by the Mexican tax authorities April 3, that implement the transfer pricing documentation and country-by-country reporting scheme set out in Action 13 of the OECD/G20 base erosion and profit shifting (BEPS) plan agreements . . .
The Cayman Islands and Belize have become members of the “Inclusive Framework on BEPS,” the OECD announced today. The inclusive framework is a group of countries that have pledged to put into place minimum standards aimed at preventing tax avoidance and improving . . .
US transfer pricing lawyers Robert Feinschreiber & Margaret Kent examine a guidance note, released last week by the UN’s Committee of Experts on International Cooperation in Tax Matters, which concerns transfer pricing issues associated with extractive industries, specifically mining and mineral extraction and oil and natural gas production . . .
The UN's Committee of Experts on International Cooperation in Tax Matters (UN Committee), during meetings held last week, released its revised and updated 2017 United Nations Practical Manual on Transfer Pricing for Developing . . .
Davide Anghileri of the University of Lausanne discusses OECD tax guidance, released April 6, which further clarifies the country-by-country reporting rules for large multinational groups . . .
The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . .
The UK's HM Revenue & Customs (HMRC) today published a policy paper titled “Amendments to Country By Country reporting 2017” and an updated policy. . .
Tax officials, during a March 28 webcast, discussed the OECD's international tax agenda, including plans to release tax and transfer pricing guidance and promote . . .
The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
"Rollback" of a transfer pricing method to resolve disputes in previous open tax years is permitted for bilateral advance pricing. . . .
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .