Transfer Pricing

Multinational

Authors address mechanics of the Berry ratio and note that the transfer pricing method may be undergoing a renaissance: Lorraine Eden, Tetiana Zakrevska / SSRN→

October 12, 2017

Americas

IRS appealing Tax Court loss in Amazon transfer pricing case

October 5, 2017

The US IRS is appealing its Tax Court loss in the Amazon transfer pricing case to the Court of Appeals for the Ninth Circuit. The IRS’s appeal, filed on September 29, will challenge a March Tax Court ruling concerning Amazon’s cost-sharing . . .

Asia-Pacific

Singapore allows cost-plus mark-up basis for routine services: KPMG→

May 11, 2017

Asia-Pacific

What the Chevron decision means for Australia and transfer pricing worldwide

May 8, 2017

Nick Drizen of BDO Australia discusses the Australian Full Federal Court’s landmark decision in Chevron, providing insight into transfer pricing for intercompany loans . . .

Americas

Mexico: transfer pricing documentation and country-by-country reporting rules finalized

April 20, 2017

Yoshio Uehara, César De la Parra, and Ignacio Mosquera of Chevez, Ruiz, Zamarripa, analyze final rules, issued by the Mexican tax authorities April 3, that implement the transfer pricing documentation and country-by-country reporting scheme set out in Action 13 of the OECD/G20 base erosion and profit shifting (BEPS) plan agreements . . .

Europe

UK country-by-country reporting guidance published

March 30, 2017

The UK’s HM Revenue & Customs (HMRC) today published a policy paper titled “Amendments to Country By Country reporting 2017” and an updated policy. . .

Asia-Pacific

New India GAAR circular aims for clarity but remains unsatisfactory

January 30, 2017

Sriram Govind of the Institute for Austrian and International Tax Law discusses a circular issued by the Indian government January 27 which contains welcome clarifications on India’s coming GAAR but also includes statements that will likely increase confusion, such as how the GAAR will be applied in some cases involving tax treaties . . .

Asia-Pacific

Updated Singapore transfer pricing guidance allows simplified method for related party loans

January 12, 2017

Singapore’s Inland Revenue Authority (IRAS) on January 12 published the fourth edition of its e-Tax Guide on transfer pricing. The new guidance includes a discussion . . .

Asia-Pacific

New Turkish transfer pricing law is consistent with OECD guidelines: KPMG→

September 13, 2016

See: KPMG.

OECD draft tackles multinational corporation tax avoidance though payments to branches

August 22, 2016

The OECD today released a draft report for countries that seek to improve their laws to counteract tax avoidance by multinationals through “branch mismatch structures.” The draft targets situations where a multinational group arranges its affairs to . . .

Europe

CCTB would have a large impact on most EU states mostly because of AGI and R&D super-deduction, paper says: European Commission→

March 18, 2019

Americas

US IRS seeks feedback on transfer pricing documentation regs

February 28, 2019

The US IRS, in a February 26 notice, has solicited feedback on whether taxpayer burdens imposed by tax regulations governing transfer pricing . . .

Asia-Pacific

Japan-Ireland tax treaty to be modified by MLI

February 11, 2019

The Japanese government on February 8 announced that a 1974 bilateral tax treaty between Japan and Ireland . . .

Asia-Pacific

Japan’s 2019 tax reform proposal restricts interest deduction, updates transfer pricing rules

December 19, 2018

Masao Yoshimura, Professor of Tax Law at the Graduate School of Law, Hitotsubashi University, discusses Japan’s 2019 tax reform proposal, released December 14 . . .

Africa

Japan tax reform to include rules aimed at reducing MNE tax avoidance, sources say: The Japan Times→

December 3, 2018

Americas

US appellate court sides with IRS in Medtronic transfer pricing royalty rate dispute

August 20, 2018

A US federal appeals court on August 16 vacated and remanded the Tax Court’s 2016 decision in Medtronic v. Commissioner, handing a win to the IRS in the latest round of this billion-dollar, long-running transfer pricing dispute over royalty rates. The United States . . .

Asia-Pacific

Australia proposes to amend “significant global entity” definition: KPMG→

July 25, 2018

G20 finance ministers consider digital economy taxation, crypto-assets, future technologies

July 23, 2018

G20 finance ministers and central bank governors, during their July 21–22 Buenos Aires, Argentina, meeting reaffirmed their commitment to reach multilateral agreement on the taxation of the digital economy. The ministers also agreed that crypto-assets could be used for tax evasion, endorsed a paper that makes tax policy recommendations . . .

Americas

Country-by-country reporting exchange agreement between US and Slovenia available

June 15, 2018

The US IRS today made available on its website a country-by-country reporting exchange . . .

Asia-Pacific

Australian Taxation Office preparing guidance on related-party interest-free loans, derivatives

December 11, 2017

The Australian Taxation Office (ATO) on December 11 announced that it intends to add two draft schedules to Practical Compliance Guideline( PCG 2017/4), which sets out the ATO’s compliance approach to cross-border related party financing arrangements and . . .

Americas

Linguanti leaves Baker McKenzie to join Morgan Lewis’s Chicago tax practice

August 9, 2017

Thomas V. Linguanti has joined Morgan, Lewis & Bockius LLP as a partner in Chicago, the firm announced August 8. Linguanti, formerlly chair of Baker & McKenzie LLP’s North . . .

Asia-Pacific

Indian transfer pricing case could signal new approach for advertising, promotional expense

May 30, 2017

India transfer pricing specialist Ajit Jain discusses a tribunal decision that adopts a new way to analyze advertisement, marketing, and promotional expenses for transfer pricing purposes. . .

Europe

Netherlands bill would increase transfer pricing documentation penalties: Robert Sledz / Thompsons Reuters Tax & Accounting→

May 3, 2017

Asia-Pacific

Vietnam adopts transfer pricing decree: Nguyen Huong Giang / VietNamNet→

March 8, 2017

See: VietNamNet.

Asia-Pacific

Japan clarifies country-by-country reporting notification requirements: EY→

February 22, 2017

See: EY.

EU court denies Belgium’s request to suspend State aid decision on excess profit tax ruling regime

August 2, 2016

The EU General Court of Justice on July 19 dismissed Belgium’s application to temporarily suspend an EU Commission decision that concludes that Belgium’s excess profits tax ruling system granted illegal State aid . . .

Americas

IRS says Facebook’s valuation of IP transfer to Ireland may have been understated by billions of dollars

July 7, 2016

A US Department of Justice lawsuit filed in Federal court on Wednesday reveals that the IRS believes that Facebook may have significantly undervalued a transfer of intellectual property . . .

Americas

More multinationals applying for US advance pricing agreements, statistics show

March 31, 2016

The US IRS on March 31 released statistics on the performance of the IRS’s Advance Pricing Mutual Agreement Program (APMA), revealing that taxpayers submitted . . .

Armenia

Armenia joins “Inclusive Framework on BEPS” to fight MNE tax avoidance

February 11, 2019

Armenia has joined the “Inclusive Framework on BEPS,” an OECD-led coalition of countries . . .

Africa

G20 leaders seek improved international tax system based on tax treaties, transfer pricing rules

December 3, 2018

G20 leaders, in a communique issued after their summit in Buenos Aires, Argentina, reaffirmed their commitment to improving the international tax system . . .

Asia-Pacific

Synthesized text of New Zealand-UK tax treaty reflects MLI changes

November 6, 2018

The UK government today released the synthesized text of the UK-New Zealand tax . . .

Asia-Pacific

Australia passes tax rules on hybrid mismatches, approves MLI

August 28, 2018

Australian laws designed to curtail multinational tax avoidance through hybrid mismatch and branch mismatch arrangments and . . .

Africa

Nigeria publishes country-by-country reporting regulations: KPMG→

June 28, 2018

Europe

Italy issues final transfer pricing regulations addressing arm’s length standard

May 15, 2018

Davide Anghileri of the University of Lausanne discusses final transfer pricing regulations issued by Italy’s Ministry of Economy and Finance on May 14 on the application of the arm’s length principle . . .

Asia-Pacific

Pakistan releases more draft amendments to country-by-country reporting rules for MNEs

February 12, 2018

Pakistan’s government on February 9 published more amendments to draft rules that establish transfer pricing documentation and country-by-country . . .

Asia-Pacific

Thailand’s Cabinet agrees to law requiring transfer pricing documentation: The Nation→

January 11, 2018

Europe

Barriguete joins Duff & Phelps’s Madrid transfer pricing practice

November 4, 2017

Pilar Barriguete has joined Duff & Phelps’s transfer pricing services practice in Madrid, the firm announced . . .

Europe

Russian court supports taxpayer in challenge to transfer pricing method: CMS→

September 11, 2017

Americas

US to exchange country-by-country reports with Australia, Estonia

August 3, 2017

The US IRS today announced that it has entered into separate agreements with Australia and Estonia to exchange country-by-country reports . . .

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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