Transfer Pricing

Africa

Tunisia signs multilateral country-by-country reporting agreement

November 29, 2019

Tunisia on November 27 signed the . . .

Digital Economy

Paris consultation reveals little unity on OECD’s “unified approach” for taxing multinational groups

November 26, 2019

More than 100 speakers lined up at a November 21–22 Paris consultation to share their views on the OECD Secretariat’s compromise proposal to update to the rules for allocating multinational group profits and related taxing rights among countries, known as the “unified approach to pillar one.” The OECD’s . . .

Asia-Pacific

BHP settles longstanding transfer pricing dispute with Australian Tax Office over Singapore marketing hub: BHP→

November 21, 2019

Asia-Pacific

New Zealand tax authority cracks down on foreign-owned wholesalers and distributors

November 21, 2019

Leslie Prescott-Haar, Stefan Sunde, & Sophie Day of TP EQuilibrium | AustralAsia LP, discuss new actions taken by the New Zealand Inland Revenue in October 2019 to ensure compliance by foreign-owned New Zealand entities that may be considered wholesalers or distributors . . .

Europe

Danish staffing company can’t deduct royalties paid to Swiss parent, High Court rules

November 19, 2019

Peter S. Andersen, Transfer Pricing Partner at Questro International, Amsterdam, analyzes a key decision of Denmark’s Eastern High Court, issued October 28, where the court agreed with the tax authority that a Danish loss-making company could not deduct royalties paid to its Swiss parent for the use of marketing intangibles . . .

Asia-Pacific

China simplifies procedure for claiming tax treaty benefits

November 17, 2019

Agnes Lo, Associate Professor, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss October 14 China State Taxation guidance that revises the procedures for claiming tax treaty benefits . . .

Digital Economy

OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals

November 17, 2019

The OECD on November 15 published more than 300 comment letters that respond to its request for feedback. . . .

Featured News

The United Nations’ effort to shape global transfer pricing policy

November 16, 2019

George L. Salis, Principal Economist and Tax Policy Advisor at Vertex, Inc., King of Prussia, Pennsylvania, discusses the United Nations’ international tax and transfer pricing work, including the outcome of the 19th Session of the UN Committee of Experts on International Cooperation in Tax Matters, held October 15-18 in Geneva . . .

Algeria

Costa Rica issues new transfer priccing documentation guidelines: KPMG→

November 15, 2019

Americas

US Tax Court resolves Eaton’s transfer pricing dispute

November 14, 2019

Elisa Kaminsky of BaseFirma, Miami, discusses the October 28 US Tax Court decision in Eaton, concerning the IRS’s cancellation of an advance pricing agreement . . .

Americas

First Look: Ninth Circuit denies rehearing in Altera

November 12, 2019

The United States Court of Appeals for the Ninth Circuit today denied a rehearing en banc in . . .

Americas

Dominican Republic budget proposes new tax on digital services

November 11, 2019

The Dominican Republic on September 26 issued its budget for fiscal year 2020, proposing new taxes on companies that operate through a digital platform, such as Netflix, Spotify, Airbnb, well as the implementation of country-by-country reporting on large multinationals, writes Elisa Kaminsky, BaseFirma, Miami . . .

Featured News

OECD releases more guidance on implementing country-by-country reporting standards

November 5, 2019

The OECD today released additional guidance for tax administrations and multinational groups on the implementation and operation of country-by-country reporting. The . . .

Americas

US, Singapore negotiating exchange of country-by-country reporting data

November 4, 2019

The US Treasury on October 31 announced that the US and Singapore are . . .

Americas

Brazil guidance addresses taxation of amounts paid under “cost-sharing” agreements

October 30, 2019

Francisco Lisboa Moreira, Tax Partner at Bocater Advogados, São Paulo, discusses important Brazil’s Federal Revenue Service guidance, issued October 2, on the tax treatment of amounts paid under a cost-sharing agreement between related group companies . . .

Europe

UK Labour Party may champion formulary apportionment, MP says: The Labour Party→

October 30, 2019

Europe

Multilateral tax treaty to enter into force for Latvia

October 30, 2019

The OECD announced on October 29 that Latvia has deposited its instrument . . .

Digital Economy

Vestager says Europe should have its own digital tax if global agreement fails, praises countries that adopt unilateral measures: Laura Kayali, Simon Van Dorpe, & Thibault Larger / Politico→

October 30, 2019

Africa

EU Parliament approves public country-by-country reporting resolution

October 30, 2019

Members of the European Parliament on October 24 adopted a resolution urging . . .

Asia-Pacific

OECD’s latest MAP review includes focus on India

October 30, 2019

The OECD on October 24 released its sixth round of Stage 1 of peer review reports on base erosion and profit shifting (BEPS) action 14, assessing India, Argentina, Chile, Colombia, Croatia, Latvia, Lithuania, and South Africa, writes Prabhakar KS of Shree Tax Chambers, Bengaluru, India . . .

Featured News

First Look: UN tax expert committee holds nineteenth session

October 28, 2019

The UN Committee of Experts on International Cooperation in Tax Matters held its nineteenth session at . . .

Africa

Estimating reliable transfer pricing profit indicators requires use of all available data

October 23, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that the arm’s length argument of many transfer pricing reports is weak because the sample is not random and the sample size of three-year data points is too small . . .

Europe

Ireland’s Finance Bill would update transfer pricing rules, adopt anti-hybrid tax provisions

October 23, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses Ireland’s Finance Bill 2019, published October 17, which includes several provisions affecting multinational enterprises including new OECD-compliant transfer pricing documentation rules . . .

Digital Economy

OECD director, tax experts, explore proposed “unified approach to pillar one” for taxing multinational groups

October 21, 2019

Julie Martin, managing editor at MNE Tax, discusses the sixth annual Tax Sunday event, held October 20 in Washington, D.C., where the OECD Secretariat’s proposed “unified approach to pillar one” was addressed by OECD tax director, Pascal Saint-Amans and other leading tax experts from government organizations, civil society, business, and academia . . .

Digital Economy

Digital services taxes rightly focus on location-specific rents, could improve global efficiency and distribution, NYU law professor argues: Daniel Shaviro / SSRN→

October 19, 2019

Digital Economy

G-24 developing countries express support for multilateral solution to taxing digital economy

October 19, 2019

The Intergovernmental Group of Twenty-Four on International Monetary Affairs (G-24), in an October 17 communique released . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Europe

First Look: Ireland publishes finance bill with international tax and transfer pricing changes

October 17, 2019

The Irish government today published Finance Bill 2019, which contains legislation . . .

Africa

Nigeria to introduce e-filing for transfer pricing related returns: PwC→

October 16, 2019

Asia-Pacific

Hong Kong tax agency clarifies country-by-country reporting thresholds for large MNEs

October 16, 2019

Hong Kong’s Inland Revenue Department today published new . . .

Digital Economy

OECD’s proposed “unified approach” would give market countries greater taxing rights over large multinationals that sell to consumers

October 10, 2019

In an effort to expedite agreement between nations on an update to the international tax rules to account for new digital business models, the OECD secretariat on October 9 proposed a compromise plan for allocating multinational . . .

Europe

Ireland Budget 2020 released

October 10, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses Ireland’s Budget 2020 measures, released by the government on October 8 . . .

Americas

Argentina issues burdensome draft transfer pricing guidance for public comment

October 7, 2019

Elisa Kaminsky, a senior associate at BaseFirma, Miami, discusses an October 2 public consultation on new Argentina transfer pricing guidance which includes significant and burdensome new requirements . . .

Asia-Pacific

Australian Taxation Office seeking full bench appeal of Glencore transfer price decision: Tom McIlroy / Financial Review→

October 7, 2019

Europe

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty

October 7, 2019

Leopoldo Parada of the University of Turin, Italy, writes about the implications of the EU General Court’s decsion in the Fiat and Starbucks state aid cases . . .

Americas

Return on assets (ROA) is an unreliable profit indicator

October 2, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that selection of “return on assets” as a profit indicator in transfer pricing can lead to intractable controversy because the term is ill-defined whereas operating profit margin and operating profit markup are more reliable . . .

Featured News

Draft “toolkit” aims to help developing countries with transfer pricing documentation

October 2, 2019

The Platform for Collaboration on Tax – a joint initiative of the International Monetary Fund, OECD, United Nations, and World Bank Group – on September 27 released a draft “toolkit” aimed at helping developing nations design transfer pricing . . .

Africa

Zambia budget includes transfer pricing measures: KPMG→

October 1, 2019

Europe

Italian Revenue clarifies new reporting option for patent box tax benefit

October 1, 2019

Gian Luca Nieddu, Head of Transfer Pricing and Tax Value Chain at Hager & Partners, Milan area, writes about Italy’s September 9 clarifications to the patent box regime . . .

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin