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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 . . .

Europe

Italy unlocks tax dispute resolution mechanism

January 6, 2021

Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses December 16 Italian tax guidance clarifying changes to Italy’s tax dispute resolution mechanism . . .

Digital Economy

Italian digital services tax is knocking at the door

January 6, 2021

Francesca Amaddeo, Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses December 17 guidance issued by the Italian tax authority that addresses Italy’s new digital service tax . .

Digital Economy

French High Court in Valueclick interprets tax treaty permanent establishment rules

January 5, 2021

Mickael Duquenne, Senior Manager and Pascal Luquet, Partner, at Grant Thornton Société d’Avocats, Paris, discuss a December 11 landmark decision of France’s Supreme Administrative Court concluding that an Irish company had a permanent establishment in France . . .

Europe

German transfer pricing amendments shift burden of proof, reveal climate of distrust

December 28, 2020

Oliver Treidler, CEO, TP&C GmbH, Berlin, discusses revised German Federal Ministry of Finance transfer pricing guidelines, released December 3, that increase taxpayer compliance burdens and grant greater powers to the tax authority . . .

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

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 . . .

Africa

Benin introduces transfer pricing private ruling procedure

December 21, 2020

Moïse Gnakouri, a Doctoral researcher at the Catholic University of Louvain, Brussels, Belgium, discusses a new law adopted by the Benin parliament on December 8 that allows multinationals to apply for transfer pricing rulings . . .

First Look: OECD guidance examines transfer pricing issues created by the COVID-19 pandemic

December 18, 2020

Today, the OECD published guidance on transfer pricing issues that arise or may be exacerbated on . . .

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 . . .

Europe

German transfer pricing guidance addresses taxpayers’ obligation to cooperate with tax office

December 16, 2020

Konstantin Sakuth of Linklaters LLP, Munich, discusses December 3 transfer pricing guidance issued by Germany’s Federal Ministry of Finance that addresses a multinational group taxpayer’s obligation to cooperate with the tax authorities concerning income allocation . . .

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 . . .

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 . . .

Europe

UK seeks feedback on proposed VAT changes that reflect digital platform “sharing economy”

December 14, 2020

The UK’s HM Treasury has requested public feedback on whether the VAT rules should be changed . . .

Europe

Blackrock’s transfer pricing battle with the UK: unexplored intercompany financing issues

December 11, 2020

Dr. J. Harold McClure, a New York City economist, discusses intercompany loan pricing issues revealed in a November 3 UK Tribunal decision favoring the UK affiliate of investment management group, Blackrock . . .

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 . . .

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 . . .

Asia-Pacific

Glencore’s Australia transfer pricing litigation – the economic considerations

December 9, 2020

Dr. J. Harold McClure, New York City, provides a detailed analysis of Glencore’s long-running transfer pricing dispute with Australia over the pricing of copper from the Cobar mines, most recently addressed by the Federal Court of Australia in a November 6 decision . . .

Europe

EU states agree to share digital platform information to aid tax collection

December 7, 2020

Francesca Amaddeo, a Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, reports that the EU Council has reached technical agreement on DAC7, concerning the exchange of information provided by digital platforms, such as Amazon and Airbnb, for tax purposes . . .

Europe

Italy updates transfer pricing regulations

December 7, 2020

Angela Valente, Diego Conte, and Alessandro Foti of De Berti Jacchia, Milano, discuss Italian transfer pricing documentation regulations issued on November 23 that, among other things, address low-value-added services, new signature requirements, and the definition of small and medium-sized entities . . .

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 . . .

Asia-Pacific

Australia tax avoidance task force raises AUD 2.7 billion (USD 2 billion) in FY 2019–20

December 4, 2020

An Australian task force established to combat tax avoidance and responsible . . .

Belgium

CJEU should reverse Belgian excess profits tax decision, Advocate General says

December 4, 2020

The Advocate General of the Court of Justice of the Europe Union (CJEU), in a December 3 opinion, advised the CJEU to overturn . . .

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 . . .

Europe

EU 2021 taxation: New Year’s resolutions

December 1, 2020

Francesca Amaddeo, a Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the EU Council’s November 27 assessment of Europe’s 2020 tax policy achievements and its plans for 2021 . . .

Asia-Pacific

Thailand clarifies transfer pricing rules for using internal and external comparables

December 1, 2020

Andrew Jackomos, Co-Managing Partner, and Rohit Sharma, Principal, Transfer Pricing, at HLB Thailand, discuss a November 6 Thailand regulation prescribing the approach that Thai tax officers should take when analyzing and adjusting the pricing of transactions between related parties . . .

Americas

Canada to propose digital tax, extend GST/HST laws to nonresident businesses

December 1, 2020

The Canadian government has announced that it will propose a new tax on multinationals that provide digital services . . .

Americas

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

November 30, 2020

Bahrain has signed and Chile has deposited with the OECD its instrument . . .

Americas

The US and Mexico’s transfer pricing approach for maquiladoras

November 30, 2020

Dr. J. Harold McClure, New York City, notes that the US’s announcement on November 16 that the US and Mexico have again agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations and discusses the appropriate arm’s length transfer pricing policies for maquiladoras . . .

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Americas

A proposed transfer pricing safe harbor for US retailers

November 24, 2020

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, MD, proposes that US state tax authorities allow US retailers to apply a safe harbor that defines the arm’s length operating profit markup based upon a formula . . .

Americas

US IRS prevails in Coca-Cola transfer pricing dispute over intercompany royalties

November 23, 2020

Dr. J. Harold McClure, a New York City economist, discusses the US Tax Court’s November 18 ruling in a transfer pricing dispute between the IRS and Coca-Cola which considered the appropriate evaluation of intercompany royalties . . .

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Africa

OECD proposes revised “minimum standards” for nations on cross-border tax dispute resolution

November 19, 2020

The OECD Secretariat has requested public feedback on proposals designed to strengthen the Action 14 minimum standards on cross-border tax dispute . . .

First Look: US Tax Court rules in favor IRS in Coca-Cola transfer pricing dispute

November 19, 2020

The US Tax Court handed a big win to the IRS on November 18 in a transfer . . .

Americas

Blackrock prevails in UK transfer pricing dispute

November 18, 2020

Liz Hughes and Anthony Crewe, of Grant Thornton UK LLP, discuss a November 3 UK First-tier Tribunal decision in a transfer pricing dispute involving US-headquartered Blackrock investment management group . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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