Americas
Transfer Pricing
Europe
Americas
Agreement reached on OECD transfer pricing guidelines for financial transactions, official says
Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .
Europe
Asia-Pacific
Africa
Europe
Asia-Pacific
Americas
Americas
Asia-Pacific
Asia-Pacific
Digital Economy
Featured News
Featured News
Digital Economy
Europe
Americas
Featured News
Europe
Americas
Europe
Europe
Asia-Pacific
Americas
Africa
Africa
Europe
Asia-Pacific
Israel Supreme Court rules stock-based compensation must be added to cost base for transfer pricing
Shlomo Hubscher and Jacky Houlie of JH & Co. Law Office analyze an April 22 Israel Supreme Court decision which concluded that companies that use the cost plus transfer pricing method must include stock-based compensation in the cost base, thus increasing the taxes paid by many multinational firms with research and development operations in Israel . . .
Americas
Brazil seeking to align transfer pricing regime with OECD norms
Francisco Lisboa Moreira of Bichara Advogados, São Paulo, discusses a joint project undertaken by Brazilian and OECD tax officials to more closely align Brazil’s international tax and transfer pricing regime with OECD guidelines, noting this project could result in changes to Brazil’s fixed margin and royalty deduction rules . . .
Asia-Pacific
Hong Kong gazettes law on joining multilateral tax agreement
Hong Kong’s Inland Revenue Department on February 2 published in the official gazette a law providing the legal framework for Hong Kong to join a multilateral tax agreement on implementing automatic exchange of information in tax matters (AEOI), automatic exchange of country-by-country reports of multinational corporations, and spontaneous . . .
Asia-Pacific
Europe
More News
Europe
Italy issues draft tax regulations on arm’s length standard, corresponding adjustments
Italy’s Ministry of Economy and Finance on February 21 released for public consultation draft regulations designed to align Italy’s transfer pricing rules with the outcome of Actions 8–10 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, writes Davide Anghileri, University of Lausanne . . .
Europe
Europe
Intragroup IP transfer was undervalued for tax purposes, Norway appeals court rules
Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss an interesting March 19 Norwegian appellate court decision which concluded that the “relief from royalty” valuation method should not have been used to determine the value of an intangibles transfer in a merger and acquisition transaction involving Dynamic Rock Support AS . . .
Americas
Europe
