Asia-Pacific
Transfer Pricing
Europe
Dutch 2022 budget plan includes tax proposals on transfer pricing, hybrids
Jian-Cheng Ku, Gabriël van Gelder, and Rhys Bane, DLA Piper Nederland N.V., discuss the Dutch government’s September 21 tax proposals for 2022, including several direct tax measures that would affect multinational enterprises, such as limiting unilateral downward transfer pricing adjustments and . . .
Europe
Belgium
Belgian court rules against retroactive application of transfer pricing guidelines
Moïse Gnakouri, Catholic University of Louvain, discusses a June 8 decision from Belgium’s Court of Appeal of Ghent in a transfer pricing dispute between the Belgian tax authorities and a taxpayer in a case involving the application of a concept introduced in OECD transfer pricing guidelines in a tax year prior to . . .
Accounting
Groups urge FASB to prioritize public country-by-country tax reporting
The US Financial Accounting Standards Board should adopt in its standard-setting agenda a requirement for companies to report information in the notes to their financial statements on the disaggregation of country-by-country income tax, according to a September 22 letter signed by 63 organizations that . . .
Americas
Europe
Cyprus
Europe
Asia-Pacific
Americas
Australia
Accounting
India announces rules for book profits tax relief related to APAs, secondary adjustments
Ashish Mehta and Sanket Shah, Khaitan & Co., discuss the Indian tax administration’s August 10 release of new rules for computing relief related to the tax on book profits in cases where there was an increase in book profits of a particular financial year on account of an advance pricing agreement (APA) or . . .
Americas
Asia-Pacific
Africa
Americas
Amgen transfer pricing dispute – is this Medtronic redux?
New York City Economist Dr. J. Harold McClure analyzes the situation surrounding the IRS’s large transfer pricing adjustments for 2010–2015 involving the intercompany pricing between Amgen’s US parent and its Puerto Rican manufacturing affiliate, with issues seeming to mirror those in Medtronic’s . . .
Americas
Europe
Europe
Ukraine clarifies application of transfer pricing rules to transactions with US transparent entities
Yuri Nikolaychuk, Rödl & Partner, discusses the Ukraine state tax service’s July 26 ruling concerning the tax implications of transactions between a Ukrainian taxpayer and a US limited liability company based in Texas, confirming that such transactions can be subject both to the transfer pricing rules . . .
Americas
Europe
Germany adopts substantial transfer pricing and anti-treaty shopping rule changes
Thomas Schänzle, Christian Port, Florian Gimmler, Justus Eisenbeiß, Christian Witthus, Kevin Prashil Brusa and Rabea Lingier, Baker & McKenzie, analyze the far-reaching, practical implications of the amendments to the anti-treaty-shopping provision and transfer pricing rules in Germany’s Withholding Tax Relief Modernization Act (AbzStEntModG), which took effect June 9 . . .
Asia-Pacific
Asia-Pacific
Asia-Pacific
Americas
Asia-Pacific
Africa
Denmark
Europe
Europe
Africa
Europe
Americas
Asia-Pacific
Asia-Pacific
Americas
Denmark
Americas
Mexico’s outsourcing schemes’ demise and its tax and transfer pricing effects
Jesús Aldrin Rojas, Managing Partner at QCG Transfer Pricing Practice, discusses tax and transfer pricing considerations for business groups in Mexico following the country’s reform to various tax and labor laws to prohibit outsourcing of personnel, published in the official gazette on April 23 . . .
