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Featured News

Asia-Pacific

China signed 21 advance pricing arrangements in 2019, report shows

November 17, 2020

Agnes Lo, Associate Professor of Teaching, Lingnan University, Hong Kong, and Raymond Wong, Associate Professor, City University of Hong Kong, discuss an October 29 report issued by China’s State Taxation Administration that provides statistics on China’s advance pricing arrangement program through 2019 . . .

Africa

South Africa considers advance pricing agreement program

November 17, 2020

The South African Revenue Service on November 11 published a discussion paper seeking public feedback . . .

Americas

First Look: US and Mexico renew of competent authority agreement on Maquiladoras

November 17, 2020

The US IRS on November 16 announced that the US and Mexico have . . .

Africa

Zambia’s transfer pricing advances and the Mopani copper mine dispute

November 16, 2020

Dr. J. Harold McClure, New York City, discusses a November 12 OECD case study on Zambia’s landmark Supreme Court victory in a transfer pricing dispute involving the Mopani copper mines and notes transfer pricing issues addressed and not addressed in the Court’s decision . . .

Africa

East African nations pledge to jointly address taxation of digital firms

November 13, 2020

Tax officials from Kenya, Uganda, Tanzania, Rwanda, South Sudan . . .

Europe

UK draft tax proposals include hybrid mismatch fixes, R&D tax credit cap

November 12, 2020

The UK government today proposed additional tax legislation for Finance Bill 2021 . . .

Americas

Uranium transfer pricing and Cameco’s battle with Canada

November 11, 2020

New York City economist, Dr. Harold McClure, notes the Canada Revenue Agency’s recent decision to file an appeal in the Cameco transfer pricing dispute and suggests that prices paid by Cameco’s Swiss affiliate to its Canadian mining affiliate for uranium may not be arm’s length . . .

Europe

Swiss government approves new law governing tax treaties

November 11, 2020

Davide Anghileri, University of Lausanne, discusses the Switzerland Federal Council’s November 4 decision to support new legislation applicable to tax treaties . . .

Digital Economy

UN to add automated digital services article to model tax treaty

November 9, 2020

The UN Committee of Experts on International Cooperation in Tax Matters has agreed to add . . .

Europe

Poland tax guidance confirms controversial position on year-end transfer pricing adjustments

November 5, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses a Poland Ministry of Finance public consultation on an explanatory note addressing taxpayers’ ability to make year-end, self-initiated, transfer pricing adjustments . . .

Americas

Colombia clarifies commodities registration rules for transfer pricing as deadlines approach

November 5, 2020

Laura Pinilla, an Associate at BaseFirma, Colombia, discusses guidance recently released by the Colombian tax office that further clarifies new rules requiring taxpayers subject to the transfer pricing regime to register commodities agreements . . .

Americas

Panama becomes 56th nation to finalize MLI

November 5, 2020

Panama has deposited its instrument of ratification for the . . .

Europe

EU court rules Romania can impute interest on intercompany loans, but what should the rate be?

November 4, 2020

Dr. Harold McClure, a New York City economist, notes the EU Court of Justice’s October 8 ruling confirming that Romania’s tax authority can require arm’s length interest rates on intercompany loans and discusses how one would determine the interest rate . . .

Africa

Burkina Faso deposits BEPS MLI ratification documents with OECD

November 3, 2020

The OECD has announced that Burkina Faso on October 30 deposited instruments . . .

Americas

Canada Revenue appeals long-running transfer pricing dispute loss to Supreme Court

November 3, 2020

The Canada Revenue Agency (CRA) has filed an appeal in the Supreme Court of Canada seeking to overturn its June 26 loss . . .

Americas

Peru to exchange tax information on companies and individuals with other nations

November 2, 2020

Yasser Zola, Transfer Pricing Manager at BaseFirma Peru, Lima, notes that according to an October 19 Peru tax authority announcement, Peru will soon begin exchanging tax information with other countries . . . .

Asia-Pacific

India retains transfer pricing tolerance range for 2019–20

October 30, 2020

Gaurav Jain, Chartered Accountant, and Priya Bhutani discuss an October 19 India Central Board of Direct Taxes announcement setting the transfer pricing tolerance range for 2019–20 . . .

Featured News

OECD releases new methodology for peer review of country-by-country reporting minimum standard

October 29, 2020

The OECD today released a new methodology for judging whether 137 countries and their tax administrations have met minimum standards . . .

Asia-Pacific

Tax treaty between Georgia and Japan has been renegotiated

October 29, 2020

Gela Barshovi, International and Georgian tax adviser and managing partner at TPsolution, notes that Georgia and Japan competent authorities on October 22 announced that they renegotiated the current tax treaty between Georgian and Japan . . .

Europe

Ireland releases tax bill, announces plan to enact interest deduction limits from 2022

October 28, 2020

Warren Novis, BDO Ireland, Dublin, discusses Ireland’s Finance Bill 2020, released October 22, which includes several tax provisions affecting multinational enterprises and Ireland’s plans to enact EU-compliant interest deduction limitations . . .

Americas

Croatia to initiate tax treaty negotiations with the United States

October 28, 2020

Ksenija Cipek, Head of Tax Risk Analysis, Ministry of Finance, Tax Administration, Croatia, discusses the Republic of Croatia’s decision to initiate proceedings to conclude a tax convention with the United States. . . .

Denmark

Denmark courts reject tax authority’s formalistic transfer pricing approach

October 28, 2020

Susi Baerentzen, Ph.D., Copenhagen, analyzes a string of transfer pricing cases decided over the past two years by Denmark’s Supreme Court and high courts which have ruled against the tax administration’s formalistic approach, the most recent example being the July 2 Western High Court ruling in the ECCO shoe case . . .

Africa

Zambia proposes changes to transfer pricing documentation requirements

October 27, 2020

Joseph Jalasi and Mailesi Undi of Eric Silwamba, Jalasi, and Linyama Legal Practitioners, Lusaka, discuss the international tax proposals in Zambia’s 2021 budget, released on September 25 . . .

Europe

EU Commission work programme reveals plan for new taxes

October 26, 2020

Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland discusses the EU’s latest tax policy priorities, as expressed in the EU Commission’s Work Programme 2021 . . .

Africa

Transfer pricing in Kenya: beyond Unilever

October 22, 2020

New York economist Dr. J. Harold McClure discusses the new Kenya chapter in the United Nations Practical Manual on Transfer Pricing for Developing Countries and Kenya’s loss in a transfer pricing dispute with Unilever . . .

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

Africa

The UN transfer pricing manual’s updated China chapter: wine and smartphones

October 20, 2020

Dr. J. Harold McClure, a New York City economist, discusses the newly revised China chapter of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released in advance of the 21st session of Committee of Experts on International Cooperation in Tax Matters . . .

Africa

UN tax committee to consider adding new automated digital services article to model convention

October 20, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss the UN Committee of Experts on International Cooperation in Tax Matters plans to consider at its 21st session a proposed new model tax convention article that addresses automated digital services income . . .

Africa

UN tax committee to weigh updates to model treaty, transfer pricing manual

October 20, 2020

The United Nations Committee of Experts on International Cooperation in Tax Matters kicked off its 21st session today, meeting virtually to discuss transfer pricing . . .

Asia-Pacific

Israel issues updated draft proposal to amend transfer pricing documentation requirements

October 20, 2020

Jacky Houlie of JH & Co. Law Office and Shlomo Hubscher of JH Consulting Ltd. discuss the Israeli government’s October 12 amended proposal to update Israel’s transfer pricing laws . . .

Asia-Pacific

Georgia offers new tax incentives for foreign IT and shipping companies

October 15, 2020

Gela Barshovi, international and Georgian tax adviser and managing partner at TPsolution, Tbilisi, Georgia, discusses an October 8 Georgia’s government decree providing new tax incentives for foreign and Georgian companies involved in shipping and information technology . . .

Americas

Colombia publishes MAP guidance for resolution of tax treaty disputes

October 15, 2020

Juana Obando, Transfer Pricing Associate at BaseFirma Colombia, discusses August 21 Colombian tax authority guidance on the procedure to request the resolution of cross-border tax disputes under Colombia’s tax treaties . . .

Digital Economy

G20 ministers vow to continue work on international tax rewrite

October 14, 2020

In a communique released after their October 14 virtual meeting, G20 finance ministers and central bank governors said they remain committed to achieving consensus . . .

Africa

OECD Pillar One: a closer look at the proposal’s impact and the questions that remain

October 14, 2020

Philippe Paumier of VECTOR TP, Paris, takes a closer look at the supporting impact analysis of the OECD blueprint on pillar one and considers the future of the proposal . . .

Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

Europe

The economics of leasing and the arm’s length standard

October 9, 2020

Dr. Harold McClure, an New York City economist, presents a model of what would compensate arm’s length lease payments and applies this model to ship leasing . . .

Denmark

Denmark tax tribunal considers sufficiency of transfer pricing documentation

October 9, 2020

Susi Baerentzen, Ph.D., Copenhagen, discusses a decision of the Danish National Tax Tribunal, published on September 24 which assesses the Danish tax administration’s discretionary transfer pricing assessment power. . . .

Americas

Peru postpones some country-by-country report submissions

October 8, 2020

Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima, discusses September 28 Peru guidance which alters the procedure for the submission of country-by-country reports on multinational group entities . . .

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

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • 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.