Transfer Pricing
US disputes need for special digital economy tax rules, seeks consensus on profit allocation issues
The highly-anticipated interim report of the Task Force on the Digital Economy (TFDE), slated for release in April, will state that countries are divided on a long-term solution for taxing the digital economy, with the US arguing that there is no need for special tax rules in this area, said Chip Harter, Deputy Assistant Secretary (International Tax Affairs) at the US Department of the Treasury. Speaking in Washington at a Tax Council Policy Institute conference held . . .
US Republican tax reform plan would rewrite international tax system
US House Republicans today presented their long-awaited tax reform bill, proposing to dramatically change the US international tax system.As expected, the Republican proposal includes a move to a territorial tax system accomplished by a foreign dividends received deduction. This is coupled with a deemed repatriation of existing earnings held offshore. The bill sets the deemed . . .
US criticizes EU probe of multinational corp tax as Apple decision nears
The Obama Administration, in a letter and white paper released today, ramped up its criticism of European Commission efforts to force large multinational firms to pay back amounts deemed illegal state aid that were allegedly received through overly generous tax rulings, known . . .
China makes major changes to transfer pricing documentation and reporting rules for multinationals
Daniel Chan, Windson Li, and Henry Ji, of DLA Piper, Hong Kong, provide a comprehensive overview of key Chinese transfer pricing documentation, inter-company transaction reporting, and country-by-country reporting rules, which were adopted on July 13 . . .
Ireland’s tax authority issues FAQs on country-by-country reporting
Irish Revenue on June 23 issued a set of frequently asked questions regarding new Irish tax legislation and regulations that require country-by-country reporting by . . .
Tax officials preview coming OECD guidance on profit splits, attribution of profits to PEs
Tax officials provided an update of international tax and transfer pricing guidance currently being developed at the OECD, including work on profit splits and on attribution of profits to permanent establishments (PEs), at Washington DC conference sponsored by the OECD, USCIB, and . . .
IMF, OECD, UN, and Word Bank Group to jointly work on multinational business tax issues
The International Monetary Fund, OECD, United Nations, and World Bank Group today released a concept note outlining their plan to work together to help governments address the tax policy . . .
EU Commission proposes measures to curb corporate tax avoidance
The European Commission today unveiled new tax proposals aimed at establishing a coordinated EU-wide approach to curb to multinational tax avoidance. The anti-tax avoidance package, or ATAP, includes a proposed directive for . . .
Tax officials preview coming OECD transfer pricing guidelines on financial transactions
Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
Draft OECD transfer pricing guidance released on hard-to-value intangibles
The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .
IRS signed fewer APAs in 2016, statistics show
The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
OECD finalizing BEPS multilateral instrument, concerned about EU state aid tax probes
Officials are putting the finishing touches on the multilateral instrument (MLI) to implement the OECD/G20 base erosion profit shifting (BEPS) measures, keeping it on track to be finalized this fall, senior . . .
Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance
Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .
G7 leaders pledge to steadily adopt BEPS international tax measures
Leaders of the G-7 nations of the US, UK, Canada, France, Japan, Germany, and Italy, following their meeting in Ise-Shima, Japan, vowed to “lead by example” by implementing the OECD/G20 base erosion profit shifting (BEPS) package in . . .
EU expected to propose public country-by-country reporting of multinationals’ tax information
The European Commission will likely propose EU-wide legislation requiring large multinationals to publicly report their European profits and . . .