Transfer Pricing
US has agreed to country-by-country tax info exchange with 11 countries, OECD says
The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
Amazon wins $1.5 billion transfer pricing dispute in US Tax Court
Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Ireland’s legal arguments in Apple State aid tax case published
Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, discusses Ireland’s arguments in the Apple State aid case before the Court of Justice of the European Union, as revealed in the government’s summary of legal proceedings, released today . . . .
UK to extend country-by-country tax reporting to partnerships
The UK’s HM Revenue and Customs today announced that it will propose amendments to existing country-by-country reporting regulations applicable to large multinational enterprises to add . . .
Australian guidance details procedure when transfer pricing adjustments affect customs values
The Australian government has released details on the how the tax office (ATO) will respond to taxpayer requests for help determining customs duty values following a . . .
Switzerland to sign BEPS country-by-country reporting multilateral agreement
Swiss tax officials intend to sign next week a multilateral agreement to implement country-by-country reporting developed under the OECD/G20 base erosion profit shifting (BEPS) plan, Switzerland’s Federal . . .
Peer review of OECD and G20 countries shows mixed progress on exchange of private tax ruling information
The OECD today released peer reviews assessing whether 44 countries have met their commitments to disclose information to other countries about the private tax rulings they grant to multinational firms. The commitments, made as a part of 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements between . . .
Transfer pricing comparables “toolkit” reflects realities of developing nations, UN official says
A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18. Michael Lennard . . .
Australia: tax guidance on cross-border related party financing released
The Australian Taxation Office on May 16 issued draft guidelines on cross-border related party financing arrangements. In the . . .
Luxembourg tax guidance addresses intragroup financing, updates ruling procedure
The Luxembourg government on December 27 published new tax guidance for intragroup financing transactions. The guidance . . .
More tax rulings under EU scrutiny for illegal state aid, Vestager says
The European Commission is scrutinizing advance pricing agreements (APAs) issued to financing companies and to other businesses for potential state aid violations EU competition commissioner Margrethe . . .
EU to require country-by-country tax reporting, limited public release of data likely
European Union finance ministers today reached political agreement on requiring EU-wide country-by-country reporting by multinational corporations and on sharing that data between tax administrations. It was also revealed today that any future. . .
The UN transfer pricing manual’s new chapter on financial transactions: the details
Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, offer a detailed analysis of the UN Committee of Experts on International Cooperation in Tax Matters’ April 8 a draft chapter on financial transactions, proposed as an update to the UN Practical Manual on Transfer Pricing for Developing Countries . . .
OECD officials discuss international tax and transfer pricing agenda
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .