Transfer Pricing

Featured News

US IRS issues frequently asked questions on transfer pricing documentation, best practices

April 17, 2020

Elisa Kaminsky of BaseFirma, Miami, discusses IRS frequently asked questions, issued April 15, that aim to provide practitioners with best practices regarding transfer pricing documentation . . .

Asia-Pacific

New South Korea transfer pricing and diverted profits tax laws enter into effect

April 16, 2020

Jay Shim and Steve Minhoo Kim of Lee & Ko, South Korea, discuss important amendments to South Korea’s international tax and transfer pricing laws that became effective on January 1 including a Korean version of a diverted profits tax and new simplified transfer pricing rules for intra-group low value-adding services . . .

Americas

US IRS signed more advance pricing agreements in 2019 than in recent years but backlog remains

April 15, 2020

The US IRS entered into 120 advance pricing agreements (APAs) in 2019, increasing its annual output as compared to the previous five years, IRS statistics . . .

Africa

Transfer pricing issues arising from the COVID-19 pandemic

April 14, 2020

Gaurav Jain, an India chartered accountant, and Priya Mani Bhutani, a New Delhi transfer pricing professional, discuss the impact of the COVID-19 crisis on transfer pricing . . .

Europe

Swedish court rules against Flir Systems, upholds tax penalties of EUR 70 M (USD 76.5 M)

April 13, 2020

Emiliha Ferrão and Madeleine Thörning, of Thorning Koponen Consulting, Stockholm, discuss a recent Swedish Administrative Court decision in Flir Systems, where the court upheld the Swedish tax agency’s conclusions regarding the tax due on the sale of IP owned by Flir Systems’ Belgium PE to a related Belgian company and also upheld the tax agency’s imposition of significant tax penalties . . .

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Asia-Pacific

Australian Taxation Office assesses Rio Tinto AUD $86.1m (USD 53.6m) for 2010–2016 alleging it sold underpriced aluminum to Singapore marketing hub: Peter Ker / Financial Review→

April 8, 2020

Denmark

Denmark extends all filing deadlines, including those for transfer pricing documentation

April 8, 2020

Michael Vorndran of Nord Advisory AS, Oslo, Norway, writes that the Danish Ministry of Taxation announced in a press release that all tax filing deadlines for the 2019 income year will be postponed, including transfer pricing documentation deadlines . . .

Africa

Seychelles releases country-by-country reporting notification forms for constituent entity, ultimate parent entity: Seychelles Revenue Commission→

April 7, 2020

Featured News

Dutch corporate tax residency and substance may be affected by COVID-19 quarantine and travel restrictions

April 6, 2020

Jian Cheng Ku, Gabriël van Gelder, and Mehdi el Manouzi, of DLA Piper Nederland N.V., Amsterdam discuss the potential impact on multinational group taxation if companies follow Dutch restrictions on public gatherings and travel in response to the coronavirus emergency, including the effect on Dutch substance and tax residency provisions, . . .

More News

“Platform for Collaboration on Tax” launches website showcasing work supporting developing countries

March 31, 2020

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) today . . .

Asia-Pacific

Australia increases the number of data validations required before computer system accepts country-by-country reports: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australian High Court clarifies definition of “associate” in BHP Billiton tax dispute

March 19, 2020

Paul McNab, a Tax Controversy Partner at PwC Sydney, discusses the March 11 decision High Court of Australia in BHP Billiton Limited v Commissioner of Taxation [2020] HCA 5) where the Court addresses the definition of “associate” for tax purposes . . .

Americas

US releases 2nd quarter update to priority tax guidance plan: US Department of Treasury→

March 16, 2020

Featured News

Nigeria’s Tax Appeal Tribunal decides Prime Plastichem transfer pricing case

March 16, 2020

Chizaram Modline Oparaji of Deloitte Middle East, Dubai, discusses a Nigerian Tax Appeal Tribunal decision, delivered February 19, finding in favor of the tax authority in a dispute over Prime Plastichem Nigeria Limited’s transfer pricing method . . .

Featured News

Poland issues controversial transfer pricing risk assessment rules

March 12, 2020

Dr. Monika Laskowska of the Center of Tax Analyses and Studies at Warsaw School of Economics discusses new Polish rules requiring multinational groups to disclose additional information to the tax office for use in transfer pricing risk assessment . . .

Africa

OECD releases 79 public comments responding to review of country-by-country reporting scheme

March 9, 2020

The OECD today released 79 comment letters it received in response to its consultation on a 2020 review of the country-by-country reporting rules . . .

Europe

Portugal adopts BEPS multilateral instrument to fight tax avoidance

March 5, 2020

Portugal has deposited its instrument of ratification of . . .

Asia-Pacific

Georgia transfer pricing: what multinational groups need to know

March 5, 2020

Gela Barshovi, Tax Advisor and Managing Partner at TPsolutions, Tbilisi, Georgia, provides an overview of Georgia transfer pricing laws and the Georgia tax administration’s practices regarding transfer pricing . . .

Europe

EU General Court to this week hear Amazon challenge to EU Commission finding’s that Luxembourg tax ruling granted State aid: Foo Yun Chee / Reuters→

March 4, 2020

Africa

South Africa 2020 Budget proposes new limits on interest deductions, loss carry-forwards

March 4, 2020

Virusha Subban, Jana Botha, and Prenisha Govender of Baker McKenzie, Johannesburg, discuss South Africa’s 2020 budget, released last week, which announces government proposals to alter the tax rules affecting multinational groups . . .

Asia-Pacific

Turkish presidential decree provides CbCR, transfer pricing documentation guidance: KPMG→

February 25, 2020

Americas

British Virgin Islands tax authorities to accept country-by-country reporting

February 24, 2020

The British Virgin Islands International Tax Authority (ITA) today announced that it will soon . . .

Digital Economy

G20 finance ministers say “unified approach” should be basis for negotiating updated tax rules for multinationals

February 23, 2020

G20 finance ministers and central bank governors, at their meeting in Riyadh, Saudi Arabia, held February 22–23, said they welcomed recent progress made by countries toward reaching . . .

Asia-Pacific

Australia issues transfer pricing guidance on issues related to projects involving the use in Australian waters of non-resident owned mobile offshore drilling units: Australian Taxation Office→

February 19, 2020

Africa

Extending transfer pricing benchmarking’s geographic scope: some thoughts on the TPED study

February 18, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, comments on a December study published by the Transfer Pricing Economists for Development (TPED) that presents a new framework for selecting and adjusting foreign comparables . . .

Featured News

The final OECD transfer pricing guidelines for financial transactions: what has changed?

February 18, 2020

Casimir Leuridan and Melanie Beirens of Zanders, Belgium, analyze the long-awaited OECD transfer pricing guidance on financial transactions, released February 11 . . .

Americas

Impact of global tax reform effort remains unclear, senior congressional staff members say

February 18, 2020

It is unknown whether the proposed update the international system for taxing multinationals, advanced by the OECD, will benefit or harm US interests, senior staff to Congress’ tax-writing committees said at Tax Council Policy Institue conference, held in Washington DC . . .

Europe

Spain to scrutinize taxpayers’ transfer pricing positions

February 17, 2020

Pilar Barriguete and Edland Graci, Duff & Phelps, Spain, discuss new Spanish guidance which describes the international tax and transfer pricing issues that the tax authorities will focus their enforcement efforts upon in 2020 . . .

Digital Economy

OECD Secretariat report summarizes international tax issues for G20 finance ministers meeting with focus on digitalization, tax transparency, BEPS, capacity building: OECD→

February 17, 2020

Digital Economy

Global tax rewrite could cost multinationals USD 100 billion annually, OECD says

February 13, 2020

Global corporate income tax due from multinational groups could increase by up to 4 percent or by about USD 100 billion annually if tax reforms currently being considered by 130+ countries are adopted, OECD officials said today during a presentation . . .

Africa

First look: OECD publishes transfer pricing guidance on financial transactions

February 11, 2020

The OECD today published its long-awaited transfer pricing guidance on financial transactions, notes Melanie Beirens, Senior Consultant, Zanders, Belgium . . .

Europe

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

February 11, 2020

Erik Koponen and Madeleine Thörning, transfer pricing specialists at Thorning Koponen Consulting, Sweden, discuss a recent Swedish tax agency decision rejecting a Puma subsidiary’s transfer pricing position following the approach to risk taken in the OECD transfer pricing guidelines . . .

Americas

Altera appeals its loss in transfer pricing/stock-based compensation dispute to Supreme Court: Aysha Bagchi / BloombergTax→

February 11, 2020

Americas

IRS to argue this week in US Tax Court that Facebook owes an additional $9 billion taxes because it undervalued IP: Richard Rubin / Wall Street Journal→

February 10, 2020

Featured News

Countries launch review of country-by-country reporting framework for multinational groups

February 9, 2020

The Inclusive Framework on BEPS, an OECD-led group of 137 countries working together on

Europe

Switzerland tax officials update intercompany loan interest rates

February 7, 2020

Elisa Kaminsky of BaseFirma, Miami, writes that Switzerland tax authorities recently issued updated safe harbor interest rates for intercompany loans for a variety of scenarios . . .

Asia-Pacific

Australian tax agency reveals plan to scrutinize non-arm’s length arrangements involving intangible assets

February 5, 2020

David Lewis, Managing Director of Duff & Phelps Australia Pty Ltd., Melbourne, discusses Australian Taxation Office (ATO) transfer pricing guidance issued January 22 which provides examples of arrangements involving intangibles that the agency considers to not be arm’s length . . .

Asia-Pacific

Cisco pays New Zealand NZ 4.6m (~USD 3m) additional tax for transfer pricing compensating adjustment: Tom Pullar-Strecker / Stuff.co.nz→

February 5, 2020

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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