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Multinational

CIAT

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

August 20, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss a recent Inter-American Center of Tax Administrations (CIAT) transfer pricing publication which proposes two measures for clarifying the application of the best method rule and thereby preventing the overuse of the transactional net margin method. . .

Multinational

Professor argues that OECD Model’s new “saving clause” conflicts with Article 23 entitlement to double tax relief: Leopoldo Parada / SSRN→

July 10, 2019
Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

Americas

CIAT develops risk model for selection of transfer pricing audit cases in Ecuador: CIAT (in Spanish)→

August 5, 2019

:  

Multinational

Saint-Amans says he “wouldn’t be surprised” if countries agreed to a minimum tax rate of about 12.5 percent in “pillar 2” digital tax revisions: Cliff Taylor / The Irish Times→

July 29, 2019
Featured News

Transfer pricing planning for oil refining, paper and pulp, and other continuous process industries

July 26, 2019

Gaurav Jain and Priya Mani Bhutani discuss transfer pricing issues associated with continuous process industries . . . 

Digital Economy

Saint-Amans hints at direction of digitalization negotiations at Munich tax conference: Jefferson VanderWolk / Bloomberg Tax→

July 9, 2019
CIAT

CIAT releases detailed proposals aimed at stopping transfer pricing abuse

July 17, 2019

The Inter-American Center of Tax Administrations (CIAT) on July 15 released comprehensive and detailed proposals aimed at preventing abusive transfer pricing, write Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium . . .

Americas

US, Monaco negotiating agreement  for exchange of country-by-country reports

July 1, 2019

The US today announced it is negotiating a competent authority agreement . . .

Multinational

Each purchase with Facebook’s proposed digital currency, Libra, would require immediate realization of taxable gain/loss: Chris Giles / Financial Times→

July 1, 2019
More News

Baker McKenzie appoints transfer pricing expert as new global head of tax

July 20, 2019

Baker McKenzie has appointed . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Featured News

G20 leaders approve digital work plan to address taxation of multinational groups

July 1, 2019

G20 leaders, at their summit in Osaka, Japan on June 28–29 endorsed a work plan developed by. . .

Europe

Multilateral tax treaty to enter into force for Norway

July 29, 2019

The OECD today announced that Norway has deposited its instrument . . .

Featured News

129-country coalition agrees to work plan to develop new international tax and transfer pricing rules

May 28, 2019

The BEPS Inclusive Framework today agreed to a work plan to develop international tax and transfer pricing rules that address the problems . . .

Asia-Pacific

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

August 9, 2019

The Australian government on August 9 published the synthesized texts of . . .

More News

UN publishes tax treaty negotiation manual

July 7, 2019

The UN has published a new version of . . .

Americas

In letter, US Senators Grassley and Wyden urge Treasury to use “all available tools” including Section 891, to stop France from enacting a DST: US Senate Committee and Finance→

June 24, 2019
Americas

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

July 23, 2019

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved. . .

Digital Economy

International tax rules should recognize value creation from scale, brands, market access, Irish Minister says: Reuters→

May 23, 2019
Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

G20

OECD report to G20 leaders highlights new developments in digitalization effort, BEPS implementation, tax transparency: OECD→

June 30, 2019
Digital Economy

G20 finance ministers endorse Inclusive Framework’s work plan for international tax reboot

June 9, 2019

G20 finance ministers and central bank governors at their June 8–9 meeting in Tsukuba, Japan, endorsed a work plan developed by a 129-country coalition called the “Inclusive Framework on BEPS” which provides . . .

Bosnia and Herzegovina

Bosnia and Herzegovina joins the Inclusive Framework on BEPS

July 11, 2019

The OECD on July 10 announced that Bosnia and Herzegovina has joined the “Inclusive Framework on BEPS” . . .

Europe

Takeaways from Italy’s new transfer pricing country profile

June 28, 2019

Gian Luca Nieddu of Hager & Partners, Milan area, Italy, discusses the latest version of Italy’s transfer pricing country profile, prepared by Italian Central Revenue, published on the OECD webpage a few days ago, which reflects the agency’s latest views on transfer pricing enforcement . . . 

Digital Economy

Professors discuss rational, advantages, and problems of pillar 2 GLOBE proposal: Joachim Englisch & Johannes Becker / SSRN→

June 10, 2019
Multinational

Professor offers alternatives to OECD’s “questionable” hybrid entity mismatch approach: Leopoldo Parada / SSRN→

June 10, 2019
Asia-Pacific

Singapore’s tax treaties with Finland and Guernsey amended by MLI

June 3, 2019

The Inland Revenue Authority of Singapore (IRAS) has announced that amendments to . . .

Albania

Albania joins Inclusive Framework on BEPS to address multinational tax issues

August 8, 2019

The OECD today announced that Albania . . .

Asia-Pacific

India deposits MLI ratification instrument with OECD

June 26, 2019

India deposited with the OECD documents ratifying the Multilateral Convention to Implement . . .

Multinational

Prof offers alternatives to OECD approach to hybrid entity mismatches:  Leopoldo Parada / SSRN→

May 16, 2019
Belgium

Belgium deposits MLI ratification instrument with OECD

June 27, 2019

Belgium has deposited with the OECD its instrument ratifying . . .

Americas

Canada ratifies BEPS MLI to fight tax avoidance by multinationals

June 24, 2019

Canada has ratified a multilateral tax treaty developed by more than 100 countries that is designed . . .

More News

OECD announces improvement to MLI matching database

June 18, 2019

The OECD today announced that it has expanded the functionality of a database it provides on its website that is . . .

Asia-Pacific

MLI to enter into force for United Arab Emirates

June 6, 2019

The United Arab Emirates deposited its instrument of . . .

Americas

USCIB worries that UN Practical Manual’s discussion of capital structures in new financial transactions appendix will lead to inappropriate recharacterization of debt vs equity: William J. Sample / USCIB→

July 22, 2019
Europe

Gibraltar joins “Inclusive Framework on BEPS” working on multinational group tax issues

July 7, 2019

Gibraltar has joined a coalition of countries working on international tax and transfer pricing issues. . .

No Picture
Europe

Swiss parliament agrees to eliminate bearer shares to avoid OECD tax blacklist: SWI swissinfo.ch→

June 24, 2019
Americas

Agreement reached on OECD transfer pricing guidelines for financial transactions, official says

June 8, 2019

Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .

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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
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    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
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 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
  • 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
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • 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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