Senegal on February 4 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 93rd jurisdiction to sign the document, and the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country . . .
The Hong Kong government on December 29 published a tax bill in its official gazette, proposing to introduce a transfer pricing regime and establish an advance pricing arrangement program. Inland Revenue (Amendment) (No. 6) Bill 2017 also adopts rules requiring transfer pricing documentation, including country-by-country reporting . . .
The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN, and World Bank Group – on January 24 released a draft toolkit addressing ways that emerging economies can overcome lack of transfer pricing comparable data . . .
The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company’s subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .
The US IRS on August 15 released its list of priority tax guidance projects for 2016-17, revealing that the agency has decided to work on issuing guidance in the areas of foreign currency contracts and country-by-country . . .
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the OECD should improve the transfer pricing guidelines on intragroup services by reducing the number of group companies allocated low value centralised services, removing the benefits test, and providing guidance on high value services. . . .
Jian-Cheng Ku and Robin Theuns of DLA Piper, Amsterdam, analyze Netherlands transfer pricing guidance released April 22 ws.hich outlines the State Secretary of Finance’s interpretation of the arm’s length principle and reflects the Ministry’s views on amendments made to the OECD transfer pricing guidelines as a result of the BEPS project.. . . .
Tax advisors, accountants, banks, lawyers, and other intermediaries who design and promote potentially aggressive cross-border tax planning schemes and, in some cases, the clients that receive such advice, would be required to meet new reporting. . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Chau Huy Quang and Cao Dang Duy of Rajah & Tann LCT Lawyers, Hanoi, discuss a new Vietnam draft law which would establish uniform transfer pricing rules, including an expansive definition of “related party transactions,” and impose new conditions on the deductibility of common expenses arising between related parties, such as interest and service fees . . .
Facebook has filed a petition in US Tax Court, contesting IRS adjustments that increased the social media giant’s royalty income by about $85 million in 2010 on account . . .
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