Transfer Pricing
137 countries adopt “unified approach” but global tax deal remains uncertain
In a statement released after their January 29–30 meeting, 137 countries that make up the “Inclusive Framework on BEPS” renewed their commitment to try to reach an agreement on an update to the tax rules for multinational groups by the end of 2020 using a two-pillar approach. The member countries also adopted the OECD’s proposed “unified approach,” with important modifications and clarifications, as the basis for further negotiations on pillar one . . .
The train has left the station: OECD tax officials discuss state of play for pillar one and two
Oliver Treidler of TP&C GmbH, Berlin discusses a January 16 tax conference sponsored by the German Federation of Industry which featured discussion and updates by OECD leadership and a German tax official concerning the negotiations surrounding pillar one and two and potential updates to tax dispute avoidance and dispute resolution mechanisms. . . .
Israeli court sides with Broadcom, concludes that business restructuring does not trigger tax
Jacky Houlie, of JH & Co. Law Office, and Shlomo Hubscher, of JH Consulting Ltd, discuss a landmark decision of Israel’s Lod District Court, released last week, which rejected the tax authorities’ position on the classification of Broadcom Israel’s business restructuring from a tax and transfer pricing perspective . . .