Transfer Pricing
The lack of transfer pricing comparables: selecting the appropriate box of apples in which to find bananas
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .
Luxembourg transfer pricing bill would adopt some BEPS changes
Dr. Paloma Schwarz Martínez, University of Luxembourg, discusses a new bill under consideration by Parliament that would incorporate some of the BEPS transfer pricing changes into Luxembourg law . . .
Tax officials address joint audits, public country-by-country reporting, developing country tax incentives
Tax experts, including officials from Germany, the IMF, World Bank Group, and OECD, offered their views on joint audits for multinational corporations, public country-by-country reporting, and tax incentives offered by developing countries at a conference held . . .
Belgium’s excess profit tax ruling system: why the Commission thinks it’s illegal State aid
Professor Edoardo Traversa and Pierre Sabbadini analyze the EU Commission’s decision, made public May 5, that Belgium’s excess profit rulings tax scheme is illegal under State aid rules. . .
Australian tax office seeking to fast-track key court disputes with multinationals
The Australian Tax Office (ATO) is working with the Federal Court in an effort to “fast-track” the resolution of strategically important tax cases, Tax Commissioner Chris Jordan said April 21 at a Senate committee hearing on multinational corporation . . .
Countries that accept BEPS minimum standards may participate in global tax effort, OECD says
Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according . . .
Part one: OECD tax consultation on digitalization features 50+ speakers, diverse viewpoints (pillar one)
More than 50 international tax and transfer pricing experts from business, academia, labor, and non-governmental organizations spoke at a March 13–14 consultation, held at the OECD in Paris, on the tax challenges of digitalization. This article addresses the first day of the consultation which concerned the “pillar one” policy proposals . . .
Brazil’s country-by-country reporting obligation
Francisco Lisboa Moreira, an attorney with Castro, Barros, Sobral, Gomes, discusses Brazil’s country-by-country reporting requirement for large multinationals, identifying unresolved questions associated with the new rules . . .
South Africa Budget includes dividend withholding tax increase
Dr. E. Brincker of Cliffe Dekker Hofmeyr, Johannesburg, discusses international tax proposals in the South Africa budget, delivered February 22, that will affect multinational corporations . . .
Australian transfer pricing guidance on marketing, sales and distribution hubs released
Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO’s approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .
OECD officials outline international tax initiatives, country-by-country reporting guidance released
OECD officials, during a December 5 webcast, discussed OECD international tax work, including just-released guidance implementing country-by-country reporting standards, the G20’s tax agenda, the BEPS multilateral instrument, OECD drafts on profit splits . . .
India-Korea tax treaty enters into force
A double tax treaty signed by India and Korea on May 18, 2015, entered into force on September 12, the government of India announced . . .
Irish tax authority introduces formal bilateral advance pricing agreement program
Irish Revenue has today released guidelines establishing a formal bilateral advance pricing agreement (APA) program to provide certainty for multinational corporation transfer pricing . . .