Transfer Pricing

OECD guidance proposes simplified transfer pricing treatment for low value-adding intra-group services

November 3, 2014

Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group services.   The guidance was released in response to Action 10 of the OECD Base Erosion and Profit Shifting (BEPS) plan, which directs the OECD to develop transfer pricing rules or special measures "to provide protection against common types of base eroding . . .

Private tax rulings granted by Luxembourg to Amazon under EU scrutiny

October 7, 2014

The European Commission on Oct. 7 announced that it has opened an in-depth investigation into whether Luxembourg granted private rulings to an Amazon subsidiary with too favorable terms, potentially violating EU rules on state aid. The 2003 tax ruling, which is still in force, sets a methodology for the payment of a tax deductible royalty by Luxembourg-based Amazon EU Sàrl to a related limited liability. . .

Irish government to investigate effect of its tax regime on developing nations

April 29, 2014

Responding to calls from the G-20 and civil society groups, the  Irish government, on April 29,  announced that it will undertake a ‘spillover analysis’ to research what effect Ireland’s tax system has on the economies of developing countries.  The Irish government will engage consultants to assist with the evaluation and has launched a public consultation, asking interested parties to make submissions on the topic. See Public Consultation.

OECD BEPS Eurasia regional meeting draws tax officials from only six nations

March 10, 2015

Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD's effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .

Roubalsky joins Denton’s Moscow office

September 5, 2014

Kirill Roubalsky has joined the Moscow office of Dentons as a senior associate in the Tax and Customs practice. Roubalsky, fomerly with Pepeliaev Group, Schekin & Partners and Muranov, Chernyakov & Partners, specializes in tax litigation, general corporate and international tax law and tansfer pricing issues. Release

EU probes whether tax rulings granted to Apple in Ireland, Starbucks in Netherlands, and Fiat in Luxembourg violate state aid

June 11, 2014

The European Commission, on June 11, announced that it is investigating whether individual transfer pricing rulings granted to Apple in Ireland, Starbucks in the Netherlands, and Fiat in Luxembourg sanctioned the allocation of too little profit to activities in those countries, thereby amounting to illegal state aid. The Commission has also initiated an infringement action against Luxembourg in connection with the matter.The decision is part of a wider investigation into whether tax rulings and . . .

-Update: The Luxembourg Finance Ministry, in a June 12 statement, said it would continue to defend against the Commission's charges of illegal state aid, and said it still has doubts about the legality Commission requests for information, see statement.

Canada signs 31 APAs in FY 2014/2015

August 21, 2015

Canada signed 31 advanced pricing arrangements (APAs) in FY 2014/2015, the most in five years, according to data released August 20 by the Canadian Revenue Agency (CRA). A total of 29 bilateral and 2 unilateral . . .

China and South Korea sign bilateral APA

June 23, 2015

China and South Korea have signed a bilateral advance pricing agreement, the Chinese goverment announced in a June 23 English-language release. The signing took place during a Sino-South Korea tax commissioners meeting . . .
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