Americas
Transfer Pricing
Europe
Americas
Africa
Africa
Americas
Africa
Africa
Europe
Multinational
Americas
Asia-Pacific
Americas
Europe
Poland clarifies treatment of dividends under transfer pricing rules
Dr. Monika Laskowska of the Center of Tax Analyses and Studies at the Warsaw School of Economics discusses guidance issued August 6 by Poland’s Minister of Finance that addresses whether a dividend payment among associated companies falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. . . .
Americas
Americas
Africa
Americas
Asia-Pacific
The Korean tax authorities’ challenge to Netflix’s transfer pricing
Dr. Harold McClure, a New York City economist, notes the Korean National Tax Service’s August 27 announcement that it is investigating the transfer pricing practices of 21 multinationals, including US technology and media multinational, Netflix, and considers what the tax service’s transfer pricing dispute with Netflix might be. . .
Americas
Africa
Americas
Asia-Pacific
Europe
Asia-Pacific
Americas
Asia-Pacific
Asia-Pacific
Americas
Public input sought on Brazil, OECD transfer pricing harmonization
Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .
Americas
Asia-Pacific
Americas
Asia-Pacific
Hong Kong revises transfer pricing guidance on advance pricing arrangements
Agnes Lo, Associate Professor of Teaching, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss the Hong Kong’s Inland Revenue Department’s July 15 revisions to guidance setting out the Hong Kong government’s interpretation and practice relating to advance pricing arrangements . . . .
Asia-Pacific
Australia addresses transfer pricing treatment of Covid-19 support payments
Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP discuss July 15 Australian Taxation Office guidance on the transfer pricing treatment of payments made under Australia’s JobKeeper program, which provides financial support to employers that have been materially affected by the Covid-19 pandemic . . .
Africa
The intercompany pricing of commodities: Alcoa versus the Australian Taxation Office
Dr. Harold McClure, an Economist based in New York City, discusses a transfer pricing dispute between the Australian Taxation Office and an Australian affiliate of US aluminum giant, Alcoa, which presents interesting questions regarding when comparable transactions should be considered uncontrolled transactions for transfer pricing purposes and how to select the best method for determining arm’s length prices for commodities such as alumina. . . .
Europe
Africa
Europe
Africa
Intercompany interest deductions in the extractive sector
Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .
