Transfer Pricing

Europe

Denmark tax bill clarifies timing rules for transfer pricing documentation

September 25, 2019

Peter S. Andersen, a transfer pricing partner with Questro International, discusses Denmark’s proposed new requirements for transfer pricing documentation which were included in a Denmark Ministry of Taxation draft bill published on September 12 . . .

Europe

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

September 24, 2019

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission assess whether an advance . . .

Digital Economy

Taxation of the digital economy, future of debt, and other OECD updates during the IFA Congress 2019 in London

September 24, 2019

Arnas Laurynas, Managing Director of Quantera Global, London, discusses some of the highlights of IFA Congress 2019, held September 8–12 in London, which brought together leading international tax and transfer pricing experts from around the world . . .

Asia-Pacific

Philippines issues transfer pricing audit guidelines: EY→

September 19, 2019

Americas

Ireland outlines arguments in Apple state aid case: Ireland Department of Finance→

September 18, 2019

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Asia-Pacific

Australia updates guidance on simplified transfer pricing recordkeeping: Australian Taxation Office→

September 17, 2019

Europe

German finance minister endorses public country-by-country reporting of MNE tax information

September 17, 2019

German tax practitioner Ninja-Antonia Reggelin discusses the changing German position on public release of country-by-country reporting data . . .

Unresolved cross-border tax disputes continue to rise, OECD stats show

September 16, 2019

Despite OECD efforts to encourage countries to more swiftly and effectively resolve of cross-border tax . . .

Belgium

EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations

September 16, 2019

The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian . . .

Asia-Pacific

Australia: Glencore’s ‘big win’ for taxpayers on transfer pricing

September 12, 2019

Ruth Butter and Stefan Sunde at TP EQuilibrium AustralAsia discuss Glencore’s recent win in a transfer pricing dispute before the Federal Court of Australia . . .

Asia-Pacific

Hong Kong tax authority updates penalty policies for international tax

September 11, 2019

The Hong Kong Inland Revenue Department announced September 4 that it has updated its webpage on penalty policies related to international tax . . .

Asia-Pacific

Hong Kong government website updated to specify transfer pricing documentation requirements: Inland Revenue Department→

September 9, 2019

Europe

Ireland proposes sweeping changes to transfer pricing laws

September 4, 2019

Warren Novis, Head of Transfer Pricing at BDO Ireland, discusses the Irish government’s proposed amendments the transfer pricing rules, released earlier this week . . .

Report assesses 116 nations’ implementation of country-by-country reporting

September 3, 2019

The OECD today released a peer review report judging whether 116 countries and their tax administrations have met . . .

Asia-Pacific

First Look: Glencore wins Australian transfer pricing case

September 3, 2019

Glencore won an AUS $92m (USD 62m) transfer pricing dispute with the . . .

Asia-Pacific

Georgia: a low-tax European country with much to offer investors

September 2, 2019

Gela Barshovi, Tax Advisor and Managing Partner at TPsolution, Tbilisi, Georgia, discusses the tax and regulatory advantages of conducting business in Georgia . . .

Americas

Canada and Switzerland deposit BEPS MLI ratification documents with OECD

August 29, 2019

Canada and Switzerland have deposited their instruments of ratification for the . . .

Digital Economy

OECD to release next digital tax draft by October, crafting country-by-country min tax, Saint Amans says: France 24→

August 29, 2019

Bulgaria

Bulgarian mandatory transfer pricing documentation rules enacted

August 23, 2019

Ekaterina Aleksova, Senior Manager at PricewaterhouseCoopers Bulgaria discusses a new law introducing mandatory transfer pricing documentation in Bulgaria which was officially published in early August . . .

CIAT

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

August 20, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss a recent Inter-American Center of Tax Administrations (CIAT) transfer pricing publication which proposes two measures for clarifying the application of the best method rule and thereby preventing the overuse of the transactional net margin method. . .

Americas

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

August 17, 2019

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary to . . .

Americas

OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, Netherlands

August 14, 2019

The OECD on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . .

Americas

CIAT develops risk model for selection of transfer pricing audit cases in Ecuador: CIAT (in Spanish)→

August 5, 2019

Multinational

Saint-Amans says he “wouldn’t be surprised” if countries agreed to a minimum tax rate of about 12.5 percent in “pillar 2” digital tax revisions: Cliff Taylor / The Irish Times→

July 29, 2019

Transfer pricing planning for oil refining, paper and pulp, and other continuous process industries

July 26, 2019

Gaurav Jain and Priya Mani Bhutani discuss transfer pricing issues associated with continuous process industries . . .

Australia

Australian tax office addresses transfer pricing, debt-equity rule interaction

July 10, 2019

The Australian Tax Office on 4 June released guidance which deals with the interaction between the transfer pricing rules and the debt-equity rules, write Leslie Prescott-Haar & Stefan Sunde, TP EQuilibrium | AustralAsia LP . . .

Americas

IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangements

August 5, 2019

The US IRS will once again examine allocations between group members of employee . . .

Europe

Ukraine to publically release results of first 12 transfer pricing cases to provide guidance to taxpayers: Volodymyr Petrov / KyivPost→

July 10, 2019

Americas

US and Curacao negotiating country-by-country reporting exchange agreement

August 14, 2019

The United States and Curacao are negotiating an agreement . . .

Americas

Brazil’s effort to align its transfer pricing rules with OECD standards

July 17, 2019

Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the status of a joint effort of the OECD and Brazil’s tax authority to reduce the gaps between Brazil’s transfer pricing regime and the OECD transfer pricing guidelines ahead of Brazil’s ascension to the OECD . . .

CIAT

CIAT releases detailed proposals aimed at stopping transfer pricing abuse

July 17, 2019

The Inter-American Center of Tax Administrations (CIAT) on July 15 released comprehensive and detailed proposals aimed at preventing abusive transfer pricing, write Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium . . .

Asia-Pacific

India Budget 2019: key international tax and transfer pricing developments

July 7, 2019

Mukesh Butani and Shreyash Shah of BMR Legal Advocates discuss India Budget 2019 which includes a few proposals that will have a material impact on cross-border taxation and transfer pricing . . .

Europe

The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?

August 2, 2019

Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting project has increased the scope for differences of opinion between tax authorities of different countries, writes Danny Beeton of Arendt & Medernach, Luxembourg . . .

Europe

Luxembourg updates filing procedure for CbC reporting: Bloomberg Tax→

July 25, 2019

Europe

Absolut wins Swedish transfer pricing dispute over application of benchmarking study and multiple year analysis

July 7, 2019

Madeleine Thörning and Erik Koponen of Thorning Koponen Consulting analyze a Sweden Supreme Administrative Court decision in a transfer pricing dispute between Swedish subsidiary, Absolut Company AB, and the Swedish Tax Agency . . .

Europe

Poland provides guidance on transfer pricing comparability for multinationals

June 25, 2019

Dr. Monika Laskowska, a partner with PwC Poland, discusses the Polish Ministry of Finance’s June 19 explanatory note addressing transfer pricing comparability analyses . . .

Americas

US IRS releases priority guidance plan third-quarter update

June 21, 2019

The US IRS on June 17 issued its third-quarter update to its 2019 priority guidance . . .

Asia-Pacific

Israeli tax authorities issue updated transfer pricing declaration Form 1385

August 12, 2019

The Israeli tax authorities recently issued an updated Form 1385, which is a declaration regarding intercompany transactions with related parties, write Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher JH Consulting Ltd . . .

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