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 . . .
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 . . .
Bijal Ajinkya and Raghav Kumar Bajaj, Khaitan & Co, discuss the Swiss tax authority’s August 13 confirmation that dividends received by an Indian resident from a Swiss company will be subject only to a 5% withholding tax rate in Switzerland, but if India does not reciprocate, the Swiss reserve the right to . . .
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 . . .
Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .
Abigail Blanco Vázquez and Álvaro de la Cueva of J&A Garrigues, S.L.P., discuss Spain’s law published on July 9 to prevent and combat tax fraud (Law 11/2021), triggering changes to various tax concepts and to the general taxation law itself. Provisions in the anti-fraud law affecting corporate income tax and . . .
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