Transfer Pricing
Tax proposals in Indian budget affect international business, experts say
India’s Budget 2016–17, offered today by Finance Minister Arun Jaitley, includes a number of tax measures of interest to international business, according to tax specialists . . .
EU finance ministers wary of anti-tax avoidance proposal
EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for . . .
US and India to begin negotiating bilateral APAs, 100 transfer pricing disputes resolved
Reassured by the successful settlement of numerous long-pending transfer pricing disputes, the US competent authority has agreed to soon begin negotiating bilateral advance . . .
Update (2/1/2016): US confirms it will accept Indian bilateral APA applications: The US IRS, on February 1, confirmed that, beginning February 16, the US competent authority will accept applications . . .
Apple to argue in State aid case that Irish subs’ profits belong to US
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission’s State aid decision against Ireland, published today in summary form, noting that Apple’s arguments diverge somewhat from Ireland’s arguments. . .
Starbucks files suit challenging Commission’s decision on State aid in tax case
The European Court of Justice has today confirmed that Starbucks filed a suit in September challenging the European Commission’s decision of October 21, 2015, which concluded that an advance pricing agreement . . .
German Federal Assembly wary of public release of country-by-country transfer pricing reports on multinationals
Tax specialist, Ninja-Antonia Reggelin, discusses the state of play in Germany regarding a Commission proposal for public release of country-by-country reports on multinationals . . .
OECD releases electronic format for exchange of BEPS country-by-country tax reports
The OECD on Tuesday released a standardized electronic format for the exchange between tax administrations of country-by-country (CbC) reports about multinational . . .
EU ‘minimum effective taxation’ of interest, royalties among Dutch Presidency’s BEPS priorities
The Dutch Presidency of the EU hopes to achieve political agreement in the coming months on adding a clause on minimum effective taxation (MET) to the interest and royalties directive, according to a roadmap of the . . .
India, UK sign bilateral advance pricing agreements
India and the UK have signed two bilateral advance pricing agreements (APAs) to resolve transfer pricing disputes, the first such agreements between the nations, India’s . . .
Mexico transfer pricing comparability adjustments, the search for consensus
Jesús Aldrin Rojas a partner at QCG Transfer Pricing Practice, Mexico City, provides a comprehensive overview of a recent conference sponsored by the Universidad Panamericana Campus Mixcoac where Mexican tax officials and transfer pricing practitioners discussed new Mexican transfer pricing guidance . . .
Ireland, US multinationals to face new tax landscape in 2018
Jim Stewart, Trinity Business School, Trinity College, Dublin discusses how EU tax authorities’ increasing challenges to the tax strategies of US multinationals, their access to information about MNE activities, US tax reform, and the net effect of ‘correlative adjustments,’ are creating a new tax environment for US MNEs, Ireland, and international taxation in general . . .