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  • International Tax and Transfer Pricing Expert Authors
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Americas

Africa

Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice

January 13, 2021

Andrew Hickman, UK consultant and former OECD Transfer Pricing Head, observes that a “mutated” form of the arm’s length principle is being applied in practice that differs from the 2017 OECD transfer pricing guidelines, and considers whether the guidelines should adopt these changes or if these mutations should be abolished . . .

Africa

OECD releases 20 comments on BEPS Action 14, new tax dispute resolution proposals

January 13, 2021

The OECD today released 180+ pages of public comments from 20 groups responding to a planned 2020 review of Action 14 of the OECD/G20 base erosion . . .

Americas

Dow Chemical and Canada’s transfer pricing dispute: litigating pennies while ignoring a large toll manufacturing issue

January 12, 2021

Dr. J. Harold McClure, a New York City economist, discusses the Tax Court of Canada’s December 18 decision in the Dow Chemical transfer pricing case, noting that the parties did not address a potential toll manufacturing issue . . .

Americas

BVI notice addresses country-by-country reporting schema update and deadlines: Virgin Islands International Tax Authority→

January 11, 2021
Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Americas

The origins of transfer pricing’s comparable profits method

January 6, 2021

Ednaldo Silva, Director, RoyaltyStat, Bethesda, Md., discusses the reasons why US IRS transfer pricing officials adopted the comparable profits method . . .

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

January 6, 2021

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Americas

Barbados deposits its instrument of ratification for the Multilateral BEPS Convention becoming the 60th to join: OECD→

January 5, 2021
Americas

EU Parliament’s plan for new tax blacklist would hit Cayman Islands: Cayman News Service→

January 5, 2021
Americas

US IRS issues agent guide on qualified dividends and capital gains rate differential adjustments: Internal Revenue Service→

January 5, 2021
Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens:  Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

   

Americas

US, Turkey negotiating exchange of MNE country-by-country reports

January 4, 2021

The competent authorities of the US and Turkey have commenced negotiations for the exchange country-by-country reports . . .

Americas

Washington State legislators may soon debate digital advertising tax: Eversheds Sutherland SALT→

January 4, 2021
Americas

The end of the “double-Irish” tax structure means that a greater share of MNE profits are taxed in the US where the R&D generating the profits is undertaken: Seamus Coffey / Irish Examiner→

January 4, 2021
Digital Economy

Colorado revises regulation to clarify that sales of streaming digital goods are subject to tax: Charles Capouet & Todd Lard / SALT Shaker→

December 24, 2020
Americas

US Congress passes stimulus bill that extends PTC and ITC for land-based wind for one year at 60%, solar ITC for two years at 26%, gives offshore wind projects a 30% ITC, extends tax credit for carbon recapture by two years: Catherine Morehouse / Utility Dive→

December 23, 2020
Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

December 21, 2020

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

Americas

Mexican proposal to block foreign digital services providers if they fail to comply with digital tax rules could violate USMCA: Inu Manak & Alfredo Carrillo Obregon / Cato At Liberty→

December 21, 2020
Americas

Peru tax authority requires multinational groups to file country-by-country reports

December 21, 2020

Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima, discusses Peru tax authority guidance, published on December 2 and December 16, addressing multinational groups’ obligation to file country-by-country reports . . .

Americas

Cayman Islands amends country-by-country reporting guidance and schema

December 21, 2020

The Cayman Islands on December 17 issued amended country-by-country reporting . . .

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

December 16, 2020

The OECD today released more than 250 comment letters in response to a request for public . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

December 15, 2020
Americas

Taxing multinational group excess profit in the US, UK, and Belgium

December 15, 2020

Dr. J. Harold McClure, New York, notes the EU Advocate General’s recent opinion concerning Belgium’s excess profits tax and discusses approaches to the taxation of these profits in the US, UK, and Belgium . . .

Africa

NGO says pillar 1 and 2 proposals don’t benefit developing countries, proposes Minimum Effective Tax Rate approach as an alternative to pillar 2: The BEPS Monitoring Group→

December 15, 2020
Americas

Canada’s bolder stance on unilateral digital taxes likely prompted by reduced fear of tariffs in Biden administration: Andy Blatchford / Politico→

December 15, 2020
Americas

US Senate follows House in passing law requiring existing and future US companies and LLCs to disclose information about beneficial owners: Jeanne Whalen / The Washington Post→

December 14, 2020
Africa

New Global Forum/ATAF toolkit helps countries set up and run exchange of information functions for tax purposes: OECD→

December 14, 2020
Americas

First Look: US releases final regs on source of income from sales of personal property

December 11, 2020

The US IRS on December 11 published final regulations (TD 9921) on the source of income from sales of inventory . . .

Americas

US makes additional corrections to regs (TD 9902) on income subject to a high rate of foreign tax: Federal Register→

December 11, 2020
Americas

US IRS corrects final regs (TD 9902) on income subject to a high rate of tax: Federal Register→

December 11, 2020
Africa

Professor presents findings of survey of high-ranking tax treaty negotiators: Yariv Brauner / SSRN→

December 11, 2020
Africa

Transactional profit indicators for the TNMM are not viable

December 9, 2020

Dr. Ednaldo Silva, Founder, RoyaltyStat, Washington DC area, explains why it is not possible to determine “transactional” profit indicators for the transactional net margin method (TNMM) in transfer pricing analysis . . .

Africa

ICAP pilot for transfer pricing audits to be made permanent, OECD says

December 9, 2020

The OECD Forum on Tax Administration (FTA), comprised of 53 member country tax administrations, has . . .

Africa

88% of countries engaging in automatic exchange of financial account information have satisfactory legal frameworks, Global Forum peer review concludes: OECD→

December 9, 2020
Americas

First Look: US publishes final and proposed PFIC regulations

December 7, 2020

The US on December 4 issued final (T.D. 9936) and proposed regulations . . .

Americas

US and Germany again agree to exchange country-by-country reports on large multinationals

December 4, 2020

The competent authorities of the US and Germany have issued a joint statement, agreeing . . .

Americas

Brazil’s Supreme Court takes up taxation of software downloads

December 3, 2020

Francisco Lisboa Moreira and Rachel Mira Lagos of Bocater Advogados, Brazil, discuss a long-running Brazilian Supreme Court proceeding, stayed on November 11, that is expected to soon clarify the taxation of software downloads . . .

Americas

A new EU-US joint agenda for global change should include fair taxation of digital economy, EU officials say: EU Commission→

December 2, 2020

Posts navigation

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 2020
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.