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.. . .
Davide Anghileri of the University of Lausanne discusses Italy's new country-by-country reporting requirements for large multinationals . . .
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
The OECD today announced that Malaysia has joined the "Inclusive Framework on BEPS," which is a group of countries that have pledged to implement tax measures to combat multinational tax avoidance designed by OECD and G20 countries in its . . . .
The New Zealand government on March 3 released a slew of tax proposals in three consultation documents all aimed at preventing tax avoidance . . .
See: KPMG Luxembourg.
JP Canavan discusses newly released draft instructions to US Form 8975, which include information on early country-by-country reporting for US-parented MNEs and on how to report 'stateless' constituent entities . . . . . .
Dr. E. Brincker of Cliffe Dekker Hofmeyr, Johannesburg, discusses international tax proposals in the South Africa budget, delivered February 22, that will affect multinational corporations . . .
See: Start Making Sense.
The Australian Taxation Office (ATO), on 22 February, released Practical Compliance Guideline PCG 2017/2 (PCG 2017/2), outlining simplified transfer pricing record-keeping options to minimise record-keeping for eligible taxpayers, writes Davide Anghileri . . .
See: Bloomberg BNA.
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission's State aid decision against Ireland, published today in summary form, noting that Apple's arguments diverge somewhat from Ireland's arguments. . .