Europe
Transfer Pricing
Africa
South Africa: transfer pricing record-keeping rules finalized
Jens Brodbeck, head of ENSafrica’s transfer pricing practice in Cape Town, discusses new South African record-keeping requirements for transfer pricing transactions which became effective October 1 . . .
Council of the European Union
Europe
UK considers adding secondary adjustment rule to transfer pricing legislation
The United Kingdom’s HM Revenue and Customs on May 26 opened a consultation on a proposal to add a secondary adjustment mechanism . . .
Europe
Apple, Google, Fiat, IKEA, McDonald’s reps to be grilled on tax avoidance by EU Parliament committee
Representatives of large multinationals will again defend their companies’ tax avoidance practices before an EU parliamentary committee. This time, Apple, Google, Fiat, IKEA. . .
Asia-Pacific
Transfer pricing specialist Bhavik Timbadia joins BMR
BMR & Associates has announced that Bhavik Timbadia has joined the firm’s transfer pricing team as a partner. Timbadia will work out of the firm’s . . .
Europe
Google’s UK tax settlement resolved transfer pricing disputes, no diverted profits tax paid
Google’s recently announced settlement with UK HM Revenue and Customs requires the company to pay additional tax on account of transfer pricing adjustments and does not include any diverted profits tax (DPT) payment, HMRC documents . . .
Americas
Americas
US Senators urge Treasury to consider retaliatory EU tax in response to State aid cases
Four influential US Senators have urged the Obama administration to examine whether it should use its regulatory authority to impose additional taxes on EU citizens and corporations in retaliation for EU State aid . . .
Europe
EU Commission to soon propose new measures to combat tax avoidance by multinationals
The European Commission will present a new package of tax proposals by the end of January to combat tax avoidance by multinationals and tax fraud, EU commissioner Pierre Moscovici told . . .
Belgium
Belgium’s excess profits tax ruling scheme violates EU State aid law, Commission concludes
The EU Commission on Monday announced that it has concluded that Belgium’s excess profits tax regime is illegal under EU State aid . . .
Americas
Europe
Transfer pricing specialist Jukka Karjalainen joins Baker & McKenzie’s UK office
Jukka Karjalainen has joined Baker & McKenzie’s UK business transformation practice as a tax leader, the firm announced January 5. Karjalainen, a transfer pricing specialist, will be advising . . .
Asia-Pacific
Asia-Pacific
Singapore updates transfer pricing guidelines
Singapore’s Inland Revenue Authority (IRAS) on January 4 published the third edition of its transfer pricing guidelines, adding new information on the cost plus method and changing the guidance to reflect Singapore’s . . .
Europe
Netherlands issues guidance on country-by-country reporting for MNEs
The Netherlands Ministry of Finance has issued guidance on new transfer pricing documentation standards . . .
Americas
BRIC countries pledge to work together to stop tax avoidance and evasion
The BRIC countries of Brazil, Russia, India, and China have agreed to strengthen cooperation in areas such as transfer pricing and automatic exchange of financial account information to jointly crack . . .
Asia-Pacific
Americas
US releases proposed regulations requiring country-by-country reporting by MNEs
The US IRS on December 21 released proposed regulations requiring annual country-by-country reporting . . .
Europe
Asia-Pacific
Australia issues guidance on country-by-country reporting
The Australian government on December 17 issued detailed guidance on newly enacted Subdivision 815-E of the Income Tax Assessment Act 1997 concerning transfer pricing documentation . . .
Africa
Developing nations detail their experiences with BEPS, react to OECD work
Tax officials from 11 developing nations described the most common practices MNEs use to shift profits out of their countries, obstacles that prevent their countries from stopping these practices, and their reactions to the OECD/G-20 base erosion profit shifting (BEPS) project, responding to a UN request for . . .
Americas
US IRS requests comments on compliance burdens associated with stock options under transfer pricing regs
The US IRS, on August 7, has requested public comments on the information collection requirements related to compensatory stock options under section 482 transfer pricing regulations . . .
Europe
Tax deals granted by Luxembourg to Amazon, Microsoft, and McDonald’s under EU scrutiny
The European Union’s competition commission has requested information from Luxembourg to determine if tax deals granted to Amazon violate state aid rules, according to unnamed sources interviewed for a July 3 FT report.
Meanwhile, the EU is scrutinizing Luxembourg’s taxation of Microsoft’s and McDonald’s operations, according to a July 4 Bloomberg article.
The actions appear to be part of a wider investigation into whether tax rulings
Council of the European Union
EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS
(Updated 12/10/2015) The European Council, during a December 8 meeting, formally agreed to an amended directive requiring EU States to exchange information automatically on advance cross-border tax rulings and . . .
Americas
US lawmakers to hold hearings on BEPS, EU State aid cases
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
Americas
Too big to tax? Vanguard and the arm’s length standard – Reuven S. Avi-Yonah / SSRN
Professor Reuven S. Avi-Yonah of Michigan Law School argues that the US IRS could launch a successful transfer pricing challenge to the fee arrangement between Vanguard’s investment manager company and its related mutual fund companies. See: SSRN.
Featured News
OECD to help developing nations address transfer pricing abuse, other BEPS concerns
The OECD will lead a guidance project designed to help tax administrations determine the price of mineral commodities for transfer pricing purposes as a part of its effort to address the tax avoidance concerns of developing nations, a . . .
Asia-Pacific
Europe
European Parliament committee to investigate tax ruling practices of EU states
The European Parliament voted February 12 to establish a special committee to investigate the tax ruling practices of EU member states. The 45-member committee . . .
Europe
UK diverted profits tax hits MNEs that avoid PE rules, route profits through tax havens
The UK government on December 10 proposed a new 25 percent tax on “diverted profits,” targeting MNEs that engage tax avoidance transactions, including MNEs that “exploit” permanent establishment (PE) rules and that reduce their tax liability through transactions that lack substance. The new tax, first announced in UK Autumn Statement 2014, affects only large MNEs, is . . .
Featured News
Asia-Pacific
Europe
France’s National Assembly passes amendment requiring public country-by-country reporting: Eurodad→
The amendment will be taken up by the Senate this week. See: Eurodad.
Europe
Asia-Pacific
Australian Senate report advocates heightened public disclosure of multinationals’ tax affairs
An interim report prepared by the Australian Senate Economic References Committee, released August 18, calls for laws mandating greater public disclosure of tax information of large . . .
Asia-Pacific
Australian draft laws introduce country-by-country reporting, double penalties for profit shifting and tax avoidance
Australia’s Treasury on July 6 released draft laws introducing country-by-country reporting documentation standards and doubling administrative penalties for multinational entities that have entered into tax avoidance or profit shifting schemes. Both measures were first announced . . .
Europe
Airbus and tax justice campaigner questioned by European Parliament committee
The EU needs to be mindful of tax competition from countries outside the EU and adopt policies that will allow EU companies to remain competitive, Airbus’s head of tax, Guillaume de La Villeguérin, told the European Parliament’s Special Committee . . .
Europe
Iceland amends transfer pricing rules
Iceland has revised its transfer pricing rules to no longer require documentation for domestic transactions, narrow the definition of related entities, and remove a reference to the . . .
