Asia-Pacific

Africa

The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office

July 20, 2020

Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .

Asia-Pacific

India widens its digital tax net by enabling tax payments

July 16, 2020

Jaiman Patel, Partner – Transfer Pricing (Financial Services), at EY India, discusses the Indian government’s July 3 release of an amended tax form to enable payment of India’s new equalisation levy, a clear indication that the government will not heed requests to defer the reporting or payment of this new tax on nonresident e-commerce operators . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .