Bhavik Timbadia and Hussain Sunel of BMR & Associates LLP discuss the newly revised draft UN Practical Manual on Transfer Pricing for Developing Countries, focusing on the India chapter, which reveals Indian tax authorities' current transfer pricing positions, including some surprising views on low value adding intra-group services . . .
The US IRS on January 19 issued guidance providing a procedure for the ultimate parent entity of a US MNE group to voluntarily file Form 8975 for early reporting periods. The filing is required effectuate . . .
Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO's approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .
Singapore’s Inland Revenue Authority (IRAS) on January 12 published the fourth edition of its e-Tax Guide on transfer pricing. The new guidance includes a discussion . . .
India and Kazakhstan have signed a protocol to amend their 1996 tax treaty, the Indian government announced today. The new protocol . . .
Bermuda, Kazakhstan, and Côte d’Ivoire have joined the "Inclusive Framework on BEPS," to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . .
Cyprus' Ministry of Finance on December 22 announced that it will issue a decree setting out the requirements for country-by-country reporting . . .
Joel Cooper of DLA Piper discusses a new World Bank handbook designed to assist developing country tax administrations with the implementation of transfer pricing rules. . .
The Luxembourg government on December 27 published new tax guidance for intragroup financing transactions. The guidance . . .
The European Court of Justice has today confirmed that Starbucks filed a suit in September challenging the European Commission's decision of October 21, 2015, which concluded that an advance pricing agreement . . .
Hong Kong's Inland Revenue Department on December 22 issued more guidance on country-by-country reporting for large multinationals, including . . .
The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company's subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
The French Constitutional Council, December 8, ruled that sections of a law establishing public country-by-country reporting by multinationals are contrary to the Constitution, writes Davide Anghileri of the University of Lausanne . . .
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .