Transfer Pricing

Americas

US, Monaco negotiating agreement for exchange of country-by-country reports

July 1, 2019

The US today announced it is negotiating a competent authority agreement . . .

Asia-Pacific

Hong Kong provides guidance on transfer pricing rules and documentation requirements

July 29, 2019

Agnes Lo, Associate Professor, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss guidance issued by the Hong Kong Inland Revenue Department July 18 setting out the IRD’s views on transfer pricing, permanent establishment, and the foreign tax deduction. . . .

Americas

Altera files Ninth Circuit petition for rehearing in challenge to US cost-sharing regulations: Steve Dixon / Miller & Chevalier→

July 25, 2019

Morocco signs multilateral agreement on exchange of country-by-country reports

June 25, 2019

Morocco has signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports, becoming . . .

Europe

Spanish appeals court rules on IKEA subsidiary’s approach to transfer pricing comparability, arm’s length range

June 24, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss the Spanish Court of Appeal’s decision earlier this year in IKEA, a transfer pricing case addressing the taxpayer’s application of the transactional net margin method (TNMM) . . .

More News

Baker McKenzie appoints transfer pricing expert as new global head of tax

July 20, 2019

Baker McKenzie has appointed . . .

Asia-Pacific

Singapore tax guide addresses transfer pricing for commodity marketing, trading

May 28, 2019

Singapore’s Inland Revenue Service on May 24 released a new E-Tax guide aimed at helping . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

G20 leaders approve digital work plan to address taxation of multinational groups

July 1, 2019

G20 leaders, at their summit in Osaka, Japan on June 28–29 endorsed a work plan developed by. . .

Americas

US urging market countries to accept only modest changes to international tax system

June 6, 2019

The US is urging countries to agree to new international tax rules that would allocate a limited amount of additional profit and related taxing rights to countries where a multinational’s customers or digital users reside. In exchange for these additional taxing . . .

129-country coalition agrees to work plan to develop new international tax and transfer pricing rules

May 28, 2019

The BEPS Inclusive Framework today agreed to a work plan to develop international tax and transfer pricing rules that address the problems . . .

Africa

Mauritius amends country-by-country reporting rules to add penalties for noncompliance

May 27, 2019

Akshar Maherally, Managing Director of WTS Tax Consulting (Mauritius) Ltd, Mauritius, discusses new rules, published May 4, that impose penalties on multinationals that do not comply with country-by-country reporting requirements . . .

Americas

US IRS investigating Uber’s 2013–14 transfer pricing position: Giles Turner / Bloomberg→

June 4, 2019

Africa

Zimbabwe enacts transfer pricing documentation law: Alois Vinga / NewZimbabwe.com→

May 17, 2019

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Cyprus

Cyprus drafting new transfer pricing law to harmonize with OECD guidelines: Annie Charalambous / In-Cyprus.com→

May 28, 2019

Asia-Pacific

UAE country-by-country reporting rules published

July 30, 2019

Saumitra R. Bhagwat and George German of Deloitte Middle East discuss new UAE Ministry of Finance transfer pricing guidance which sets out country-by-country reporting compliance obligations for multinational corporation groups. . .

Denmark

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

July 23, 2019

The Danish tax administration on July 12 published a decree specifying new transfer pricing documentation rules and allowing some transfer pricing cases to be reopened where discretionary assessments were made, write Johnny Bøgebjerg and Henrik Lund of KPMG Acor Tax, Denmark. . . .

Asia-Pacific

China APA report shows government’s continued reliance on transactional net margin method

June 18, 2019

Agnes Lo, Associate Professor, Lingnan University, Hong Kong, and Raymond Wong, Associate Dean at City University of Hong Kong, discuss China’s State Taxation Administration’s most recent report on its advance pricing arrangement program . . .

Asia-Pacific

New Zealand digital services tax update

June 11, 2019

Leslie Prescott-Haar, Stefan Sunde and Sophie Day of TP Equilibrium AustralAsia discuss a consultation launched by New Zealand Inland Revenue June 4 proposing a 3 percent digital services tax . . .

Digital Economy

G20 finance ministers endorse Inclusive Framework’s work plan for international tax reboot

June 9, 2019

G20 finance ministers and central bank governors at their June 8–9 meeting in Tsukuba, Japan, endorsed a work plan developed by a 129-country coalition called the “Inclusive Framework on BEPS” which provides . . .

Americas

New Peru transfer pricing guidance addresses related-party share transfers

May 23, 2019

Carlos Vargas Alencastre and Franz Salazar Anccasi of TPC Group, Lima, Peru, discuss new Peruvian transfer pricing guidance released May 16 . . .

Europe

Takeaways from Italy’s new transfer pricing country profile

June 28, 2019

Gian Luca Nieddu of Hager & Partners, Milan area, Italy, discusses the latest version of Italy’s transfer pricing country profile, prepared by Italian Central Revenue, published on the OECD webpage a few days ago, which reflects the agency’s latest views on transfer pricing enforcement . . .

Europe

Netherlands establishes expert commission to examine how to make multinational taxation “more fair”: John O’Donnell & Toby Sterling / Reuters→

June 12, 2019

Albania

Albania joins Inclusive Framework on BEPS to address multinational tax issues

August 8, 2019

The OECD today announced that Albania . . .

Europe

Ireland updates list of countries with which it exchanges information on tax rulings: Tax and Duty Manual Part 35-00-01→

June 10, 2019

Americas

First look: Altera reversed on appeal, US cost sharing regs are valid

June 9, 2019

The United States Court of Appeals for the Ninth Circuit on Friday reversed the Tax Court’s decision in Altera, finding that . . .

Africa

Zimbabwe introduces digital economy tax, transfer pricing filing requirement

June 2, 2019

Walker Nyachowe, Founder & Managing Director, of Walker Consulting Services, discusses Zimbabwe’s 2019 budget which introduces a new tax on the digital economy and new transfer pricing return filing requirements . . .

Europe

Switzerland could lose CHF10 billion (USD10.2 billion) tax if global corporate overhaul requires companies to be taxed where sales generated: SWI swissinfo.ch→

July 22, 2019

Europe

Ireland’s Tax Strategy Group releases paper on corporation tax in advance of Budget 2020: Ireland Department of Finance→

July 17, 2019

Americas

US IRS notes updates to country-by-country reporting instructions

July 10, 2019

The US IRS today notified taxpayers that that updated . . .

Belgium

Belgium deposits MLI ratification instrument with OECD

June 27, 2019

Belgium has deposited with the OECD its instrument ratifying . . .

Americas

Canada ratifies BEPS MLI to fight tax avoidance by multinationals

June 24, 2019

Canada has ratified a multilateral tax treaty developed by more than 100 countries that is designed . . .

More News

OECD announces improvement to MLI matching database

June 18, 2019

The OECD today announced that it has expanded the functionality of a database it provides on its website that is . . .

Americas

US IRS large business unit withdraws cost sharing arrangement directive

June 12, 2019

The US IRS’s Large Business and International Division in a notice published June 4, but dated and effective May 21, has announced . . .

Belgium

Belgium transfer pricing reporting burdens reduced through legislation

June 2, 2019

Geoffroy Galéa of Laga (Deloitte Legal) and Laura Deroy and Florence Siccard of Deloitte, Belgium, discuss new legislation introduced in Belgium on May 15 that decreases in the compliance burden related to the transfer pricing reporting obligations of multinational groups . . .

Africa

Seychelles publishes country-by-country reporting regulations

May 28, 2019

The government of Seychelles on April 23 published country-by-country reporting regulations in the . . .

Asia-Pacific

India considering barring auditors from more categories of non-audit work, official says: Injeti Srinivas / Live Mint→

May 13, 2019

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