Transfer Pricing

Americas

US IRS proposes to withdraw controversial Section 385 debt-equity documentation regulations

September 23, 2018

The US IRS on September 21 proposed to revoke the hotly contested Section 385 debt-equity documentation regulations and work toward developing . . .

Asia-Pacific

Australian Taxation Office to focus on migration of IP offshore, official says: Nassim Khadem / The Sydney Morning Herald→

July 18, 2018

Asia-Pacific

New Zealand passes BEPS bill to prevent multinational tax avoidance

June 27, 2018

New Zealand’s parliament has passed the Taxation (Neutralising Base Erosion and Profit Shifting) Bill, aimed at curtailing tax avoidance by multinationals, Revenue Minister . . .

Americas

IRS signed 116 advance pricing agreements in 2017

March 30, 2018

The US IRS today released statistics on the performance of its advance pricing agreement (APA) program in 2017, revealing that the tax agency signed 116 APAs that year. APA are agreements signed between the tax agency and multinational taxpayer resolving transfer pricing . .

Americas

Cayman Islands issues notice on country-by-country reporting for multinationals

February 9, 2018

The Cayman Island government on February 2 published an advisory for multinational corporations on country-by-country reporting in advance of the release of planned guidance on the topic. The government . . .

Americas

EU Parliament adopts controversial report on tax avoidance and evasion

March 27, 2019

Davide Anghileri of the University of Lausanne, Switzerland, writes that the EU Parliament endorsed a report March 26 that calls out seven member states for their role in facilitating aggressive tax planning and recommends countermeasures against the US should it fail to provide FATCA reciprocity . . .

Denmark

Denmark finance minister endorses global minimum tax for multinational groups, common tax base

March 4, 2019

Denmark’s ruling party, Venstre, supports the global adoption of a minimum tax on multinational group profits, Denmark’s finance minister said on March 3. The minister also . . .

First Look: EU investigating Netherlands tax rulings granted to Nike for state aid violations

January 10, 2019

The European Commission today announced that it has opened in-depth investigations into tax . . .

Asia-Pacific

Cambodia changes transfer pricing rules for related party loans

September 23, 2018

Sujeet Karkala of Sciaroni & Associates discusses the Cambodia tax authority’s new transfer pricing instruction, issued August 21, which addresses the interest rates to be applied to related-party loans . . .

Europe

Ireland sets out plan to exchange info with other EU States on private tax rulings signed with multinationals

May 7, 2018

Irish Revenue, on May 7, updated its tax guidance to include its plan to implement an EU directive requiring governments to automatically exchange information with other EU States about the private cross-border tax rulings and advance pricing agreements they sign with multinational . . .

Americas

US IRS to amend country-by-country reporting regulations to protect national security

March 30, 2018

The US IRS today announced that it will amend its guidance for large multinationals on country-by-country reporting obligations to prevent reporting that jeopardizes national . . .

Europe

Irish tax authority clarifies transfer pricing rules for low-value intra-group services

March 19, 2018

Irish Revenue on March 15 provided new guidance taxpayers on Ireland’s simplified transfer pricing approach to low-value intra-group . . .

Europe

Commission publishes opening decision in Huhtamäki state aid probe

May 7, 2019

The EU Commission on May 3 published . . .

Asia-Pacific

Proposed India profit attribution rules reject OECD approach, add “sales” and “users” as apportionment factors

April 24, 2019

Madhan N of PricewaterhouseCoopers Private Limited, India, discusses the Indian government’s controversial proposal for new rules for attributing profits to Indian permanent establishments . . .

UN tax committee releases draft transfer pricing chapter on financial transactions, other docs ahead of meeting (Updated)

April 10, 2019

The UN has released draft updates to the United Nations Practical Manual on Transfer Pricing for Developing Countries — including a key chapter on financial transactions — and more . . .

Americas

US advance pricing agreement applications surged in 2018, data shows

March 27, 2019

The US IRS today issued its annual report providing statistics on its advance pricing agreement (APA) program. The data reveals a . . .

Asia-Pacific

Hong Kong extends CbCR deadline

March 25, 2019

The Hong Kong government has extended the deadline for Hong Kong entities . . .

Americas

Facebook’s trial in $5 billion US transfer pricing dispute extended to Feb. 2020: Sony Kassam / Bloomberg Tax→

January 4, 2019

Switzerland to end special tax allocation practices for new principal companies, finance branches

November 27, 2018

The Swiss government on November 14 announced that it will end special taxpayer-favorable allocation rules for new principal companies and Swiss finance branches, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne, . . .

Asia-Pacific

Israeli transfer pricing guidance addresses low-interest loans

October 4, 2018

Jacky Houlie and Shlomo Hubscher of JH & Co. Law Office, Tel Aviv-Yafo, Israel, discuss a new circular produced by the Israeli tax authorities addressing transfer pricing aspects of low-interest domestic loans . . .

Canada

What the UK’s new transfer pricing and diverted profits tax statistics tell us

August 1, 2018

Liz Hughes, a partner with Grant Thornton UK LLP, discusses the UK’s 2017–18 transfer pricing and diverted profits tax statistics, released July 31, noting several interesting trends . . .

Asia-Pacific

Indian advance pricing agreement uses customs value as arm’s length price

March 30, 2018

Mumbai advisor Ajit Jain writes that India’s Central Board of Direct Taxes has recently entered into an advance pricing agreement where customs values was accepted as arm’s length price for transfer pricing purposes . . . .

Asia-Pacific

India hits the 200 APA milestone, signs first pact on advertising, promotional expense

March 5, 2018

Transfer pricing and tax litigator Ajit Jain discusses India’s recent progress signing advance pricing agreements with multinationals and notes that the first unilateral APA dealing with the controversial topic of advertisement marketing, and promotional expenses has been concluded . . .

Americas

Morgan Lewis nabs three more Baker McKenzie tax pros

February 5, 2018

Morgan Lewis today announced the expansion of its Chicago tax team, adding three new partners: Joshua Richardson, Adam Beckerink, and Michael Liu. Richardson, Beckerink, and Liu are formerly with Baker McKenzie. They join Tom Linguanti . . .

Asia-Pacific

Israeli court uses flawed logic in key transfer pricing decision

June 29, 2017

Professor Rifat Azam, Radzyner School of Law, Herzliya discusses the Israeli District Court’s decision in Getko Ltd vs. Kfar Saba Assessing Officer, which strives to develop transfer pricing principles and guidelines in the Israeli tax law context . . .

Multinational

Countries imposing new nexus rules to tax nonresident enterprises, resetting source v. residence: Gary D. Sprague / Bloomberg BNA→

February 15, 2017

See: Bloomberg BNA.

Americas

New Mexican APA rules allow tax authority site visits: PWC→

August 7, 2016

See: PWC.

Europe

Russian draft law introduces country-by-country reporting: EY→

April 21, 2016

See: EY.

Leaked EU directive for public country-by-country reporting allows aggregation of third country tax data

March 22, 2016

A proposed EU directive would require public country-by-country reporting by multinationals on worldwide operations broken down by EU member states, but disclosure of only aggregated data for non-EU operations, according to a leaked. . .

Americas

NGO effort to cast US MNEs as tax dodgers has succeeded, Stack says: Alex M. Parker / Bloomberg BNA→

March 3, 2016

See: Bloomberg BNA.

OECD extends comment deadline for international tax consultation on digitalization

February 19, 2019

The OECD today announced that the deadline to provide public . . .

International Monetary Fund

IMF paper surveys tax avoidance via transfer mispricing, debt shifting, treaty shopping, tax deferral, corporate inversions; assesses effects on countries; notes research blind spots: Ruud de Mooij / International Monetary Fund→

January 28, 2019

Digital Economy

UN Committee of Experts meets to advance international tax and transfer pricing agenda

October 24, 2018

MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne, discusses the Committee of Experts on International Cooperation in Tax Matters seventeenth session, held in Geneva on October 16–19 . . .

Asia-Pacific

US, Austria sign agreement to exchange country-by-country reports on multinationals

August 24, 2018

The US and Austria have signed a competent authority agreement to exchange country-by-country reports on multinationals operating in their countries, US Treasury . . .

Asia-Pacific

UAE joins “Inclusive Framework on BEPS”

May 16, 2018

The OECD today announced that the United Arab Emirates has become the 116th jurisdiction to join the . . .

Denmark

Microsoft wins Danish transfer pricing case involving remuneration for marketing activities: Donal O’Donovan / Independent.ie→

March 29, 2018

EU Parliament votes for common consolidated tax base

March 18, 2018

The European Parliament on March 15 voted in favor of a plan to establish a common consolidated corporate tax base (CCCTB) in the EU. The CCCTB, passed . . .

Asia-Pacific

Cognizant’s Indian subsidiary hit with Rs 2,500 crore (USD 375 million) tax bill from transfer pricing adjustment: Hemamalini Venkatraman / DT Next→

January 9, 2018

Americas

Miesel to lead Mazars’s US transfer pricing practice

August 15, 2017

Victor H. Miesel has joined Mazars USA as a partner, national transfer pricing practice leader, and chief economist, Mazars announced . . .

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

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