Joel Cooper, co-head of international transfer pricing at DLA Piper, London, reports on a new WCO instrument that addresses use of transfer pricing documentation in assessing customs values. . . .
Davide Anghileri of the University of Lausanne discusses Court of Justice of European Union’s May 31 decision in Hornbach-Baumarkt which concluded that German transfer pricing legislation is valid and found that the role of the parent company as a shareholder of a non-resident company may be taken into account in assessing a non-arm’s length related-party transaction . . .
The European Commission on December 18 opened another State aid investigation into private tax rulings granted by an EU nation to a large multinational – this time the focus on whether the Netherlands grated special tax treatment to an IKEA subsidiary. The Commission is investigating Dutch tax rulings . . .
The OECD on October 25 released public comments from 52 individuals and groups on the design of new international tax rules for digital firms. The comments aim to help an OECD task force prepare an interim report on the issue, to be presented to G20 finance ministers in April 2018. It is widely acknowledged that the current . .
Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .
The OECD today released 107 comment letters, mostly from business representatives, that respond to two OECD discussion drafts providing for common tax rules to be used to allocate multinational corporation profits among the countries in which they operate. Fifty-five comment letters relate to the OECD’s proposed revisions to its transfer pricing . . .
The OECD on August 24 released letters from 14 organizations responding to its request for comments on draft conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines titled
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G20 finance ministers and central bank governors, during their July 23–24 meeting in Chengdu, China, approved a plan that sets out objective criteria to be used to label countries as “non-cooperative” for tax transparency . . .
The EU Commission took tentative steps toward reducing harmful tax competition among EU member countries today, publishing European Semester country reports that identify seven EU countries as potentially facilitating tax avoidance by multinationals. The Commission today also released a taxation paper detailing economic evidence that suggests that particular tax avoidance structures , , ,
US international transfer pricing attorneys Robert Feinschreiber and Margaret Kent discuss guidance developed during the OECD/G20 base erosion profit shifting (BEPS) project which applies transfer pricing concepts to contracts. . .
The OECD on July 4 released 33 comment letters received in response to its discussion draft on the development of a multilateral instrument to implement the tax treaty provisions in the final OECD/G20 base erosion profit shifting (BEPS) plan reports. All the comment letters released, except for one, submitted by the BEPS Monitoring . . .
Large multinational corporations operating in Europe would be required to publicly disclose tax information on a country-by-country basis under an EU Commission proposal, unveiled April 12, which is already drawing criticism from both . . .
The highly-anticipated interim report of the Task Force on the Digital Economy (TFDE), slated for release in April, will state that countries are divided on a long-term solution for taxing the digital economy, with the US arguing that there is no need for special tax rules in this area, said Chip Harter, Deputy Assistant Secretary (International Tax Affairs) at the US Department of the Treasury. Speaking in Washington at a Tax Council Policy Institute conference held . . .
Davide Anghileri of the University of Lausanne discusses an EU Court of Justice ruling, delivered September 7, which concludes that France violated EU law when it applied a general antiabuse rule to deny a withholding tax exemption for dividends distributed by a resident subsidiary to a company controlled by a resident of a non-EU State . . .
The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .
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