Transfer Pricing
OECD set to release 2017 transfer pricing guidelines, clarify MLI effect on tax treaties, officials say
The OECD expects to soon release an important update to its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, tax officials said during a June 26 webinar. Officials also discussed the OECD’s coming release of a discussion draft . . .
Botswana becomes 99th country to join BEPS inclusive framework
The OECD announced June 9 that Botswana has joined the “Inclusive Framework on BEPS,” becoming the framework’s 99th member. The . . .
India-Korea bilateral advance pricing agreements can include rollback, Indian tax board says
“Rollback” of a transfer pricing method to resolve disputes in previous open tax years is permitted for bilateral advance pricing. . . .
Brazil, Guernsey, Jersey, Isle of Man, Latvia sign agreement for exchange of tax reports on multinationals
Brazil, Guernsey, Jersey, the Isle of Man, and Latvia have signed a multilateral agreement which sets out the parameters for the automatic exchange between tax administrations of country-by-country tax reports on . . .
Starbucks State aid decision published by EU Commission
The EU Commission today published a non-confidential version of its decision concluding that an advance pricing agreement (APA) granted to a Starbucks subsidiary by the Netherlands is illegal State aid and ordering recovery of the . . .
Update: transfer pricing and customs valuation case study published on WCO website
Joel Cooper of DLA Piper, London, follows up his report from last week, analyzing the newly-released text of WCO guidance on the use of a transfer pricing studies employing the TNMM method to prove customs values. . .
Key UN international tax committee elects leaders, sets new agenda
Davide Anghileri of the University of Lausanne, an MNE Tax contributing editor, discusses a meeting of the UN Committee of Experts on International Cooperation in Tax Matters, held in Geneva 17– 20 October, where new committee co-chairs were elected and subcommittee assignments were set, including assignments for a new subcommittee on the digitization of the economy . . .
Duff & Phelps acquires Quantera Global Asia
Duff & Phelps, a global valuation and corporate finance advisor firm, announced May 16 that it has acquired Quantera Global Asia Holding, a transfer pricing . . .
New Zealand: permanent establishment, transfer pricing rules proposed to combat tax avoidance
The New Zealand government on March 3 released a slew of tax proposals in three consultation documents all aimed at preventing tax avoidance . . .
EU Code of Conduct Group to assess EU tax regimes using modified nexus, adopt BEPS transfer pricing rules
On 17 November, the EU Code of Conduct Group published a report on the work done by a subgroup during the Slovak Presidency on the clarification of the third and fourth criteria (i.e., substance and internationally accepted principles) of . . .