Transfer Pricing

Denmark

Denmark Supreme Court rules in Tetra Pak transfer pricing case

April 29, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Supreme Court’s April 26 ruling in a landmark transfer pricing case involving a Danish company Tetra Pak that produced and sold plants for manufacturing ice cream . . .

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Americas

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Europe

Spanish guidance clarifies transfer pricing arm’s length range

April 28, 2021

Mario Ortega and Íñigo García, J&A Garrigues, S.L.P., discuss Spain’s February 24 transfer pricing guidance on arm’s length price . . .

Europe

Poland clarifies its unique definition of “controlled transaction” for transfer pricing purposes

April 22, 2021

Dr. Monika Laskowska, Center of Tax Analyses and Studies, discusses Poland’s early April launch of a public consultation on new transfer pricing guidance defining controlled transactions . . .

Asia-Pacific

Maldives publishes advance pricing arrangement regulations

April 22, 2021

Zaina Zahir, CTL Strategies, discusses the Maldives Inland Revenue Authority’s advance pricing arrangement regulations published on March 16 . . .

Asia-Pacific

Netflix Korea reports its 2020 financials: transfer pricing implications

April 21, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Netflix’s new 2020 financial reporting in South Korea . . .

Digital Economy

UN committee considers updates to model tax treaty, developing nation tax guidance

April 21, 2021

The UN Committee of Experts on International Cooperation in Tax Matters has released documents that reveal that significant changes are proposed for the United Nations Model Double Taxation Convention between Developed and Developing Countries and UN guidance addressing . . .

Americas

Canada’s 2021 budget includes proposals on digital taxes, profit shifting, interest deductibility

April 20, 2021

Canada’s Budget 2021, presented by Finance Minister Chrystia Freeland on April 19, proposes several significant tax measures affecting multinational enterprises . . .

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

April 19, 2021

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Denmark

Danish Ministry of Taxation admits defeat in important transfer pricing case

April 14, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Ministry of Taxation’s March 25 announcement that it was withdrawing its challenge in a 2018 transfer pricing dispute . . .

Americas

Avery Dennison wins Chile transfer pricing dispute over intercompany loans, distributor margin

April 14, 2021

Dr. J. Harold McClure, New York City, discusses the multinational manufacturer Avery Dennison Corporation’s March 31 win in its transfer pricing dispute with the Chilean tax authority. . .

Asia-Pacific

India reduces transfer pricing filing burdens, increases reporting thresholds

April 13, 2021

Gaurav Jain, Chartered Accountant, and Priya Bhutani, New Delhi, India, discuss April 5 amendments to India’s transfer pricing guidance relating to the master file and country-by-country reporting . . .

Africa

Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available

April 12, 2021

MNE Tax has obtained a copy of a slide presentation outlining the US’s latest “Pillar One” and “Pillar Two” proposals for the reform of the international system for multinational group taxation. . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Europe

Peru tax authority addresses appropriate method for intra-group services under prior law

April 5, 2021

Carlos Vargas Alencastre of TPC Group, Peru, discusses the Peruvian tax administration’s March 18 guidance clarifying the transfer pricing rules applicable to intragroup services. . .

Asia-Pacific

China simplifies unilateral advance pricing arrangement procedures for some taxpayers

April 1, 2021

Agnes Lo, Lingnan University, and Raymond Wong, City University of Hong Kong, discuss China’s State Taxation Administration’s March 19 guidance simplifying unilateral advance pricing arrangement procedures for some taxpayers. . .

Americas

Tax havens begin sharing information about entities that earn income from IP, other mobile activities

March 31, 2021

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Proposed OECD model tax treaty updates cover transfer pricing for interest payments, corresponding adjustments

March 31, 2021

The OECD on March 29 proposed changes to its model tax convention commentary that would alter language regarding the arm’s length treatment of interest payments between associated enterprises located in different countries and clarify a state’s obligation . . .

Americas

US IRS shortened completion time for advance pricing agreements in 2020 but backlog remains

March 31, 2021

The US IRS cut the median time to complete advance pricing agreements (APAs) down to 32.7 months in 2020, a drop of over six months from last year, its best completion time in five years, IRS statistics published on March 30 reveal. . .

Transfer Pricing

States show renewed interest in transfer pricing agreements: JDSupra→

March 26, 2021

Europe

UK consults on aligning transfer pricing documentation requirements with OECD approach

March 24, 2021

The UK HM Revenue and Customs is considering potential new transfer pricing documentation requirements that would require businesses to prepare and provide specific documentation to support their transfer pricing . . .

Europe

Netherlands legislative proposal tackles transfer pricing mismatches

March 24, 2021

Jian-Cheng Ku and Tim Mulder, of DLA Piper Netherlands N.V., discuss the Dutch government’s publication on March 4 of its legislative proposal to tackle double non-taxation resulting from transfer pricing mismatches. . .

Greek transfer pricing guidance addresses the COVID-19 pandemic

March 24, 2021

Emmanouela Kolovetsiou-Baliafa of KG Law Firm, Athens, Greece, discusses a Greek Independent Authority for Public Revenues circular providing guidance on the transfer pricing implications of the COVID-19 pandemic. . .

Asia-Pacific

Mongolia’s first transfer pricing assessment – what could be the issues?

March 23, 2021

Dr. J. Harold McClure, New York economist, discusses the issues surrounding Mongolia’s first transfer pricing assessment. . .

Asia-Pacific

Georgia amends transfer pricing rules for APAs, reduces thresholds

March 23, 2021

Gela Barshovi of TPsolution, Tbilisi, Georgia, discusses March 2 Georgia Ministry of Finance guidance amending the transfer pricing rules concerning the unilateral advance pricing agreement procedure . . .

Asia-Pacific

Bahrain introduces country-by-country reporting requirements

March 23, 2021

Abdulrahman Bucheeri and Raman Ohri of Keypoint Solutions, Manama, discuss Bahrain ministerial guidance introducing country-by-country reporting requirements, released on February 4 . . .

Asia-Pacific

Mongolia issues first transfer pricing assessment

March 18, 2021

The Mongolian government has issued its first transfer pricing tax assessment, hitting a mining company with a tax bill of approximately USD 228 million and a denial of USD 1.5 billion in carried forward . . .

Europe

Public country-by-country reporting is inevitable, EU Commission official says: Naomi O’Leary / The Irish Times→

March 18, 2021

Europe

Ireland consults on adoption of authorized OECD approach for attributing profits to branches

March 17, 2021

Ireland’s Department of Finance on March 16 launched a public consultation on its proposal to adopt into Irish law the “authorized OECD approach” for the attribution . . .

Americas

Canadian mining company seeks NAFTA arbitration in Mexico transfer pricing dispute

March 17, 2021

First Majestic Silver, a publicly traded Canadian mining company, has resorted to international arbitration to resolve an ongoing transfer pricing dispute with the Mexican government over tax reassessments the government made in conflict with the terms of an advance pricing agreement. . .

Asia-Pacific

Transfer pricing for Indian software distribution affiliates

March 17, 2021

New York City economist, Dr. J. Harold McClure, notes that Indian tax authorities may take a closer look at transfer pricing following their loss in a landmark decision involving the taxation of foreign-based software providers . . .

Americas

US Tax Court decision in Coca-Cola is at odds with economic principles

March 3, 2021

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, Md., identifies flaws in the US Tax Court’s decision in the Coca-Cola transfer pricing dispute . . .

Africa

Zambia introduces country-by-country reporting

March 3, 2021

Rubeena Dina and Kennedy Munyandi, of GTS Africa, discuss the Zambian government’s issuance of transfer pricing regulations addressing country-by-country reporting, which became effective January 1 . . .

Europe

EU public country-by-country reporting: final call

March 2, 2021

Francesca Amaddeo a Lecturer-Researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses important EU developments regarding public country-by-country reporting . . .

Africa

US drops demand that “pillar one” global tax compromise be a safe harbor

February 26, 2021

The US will no longer require that any coordinated “Pillar One” update to the international tax and transfer pricing rules be drafted as a “safe harbor.” The announcement . . .

Europe

ActionAid, Christian Aid Ireland, Oxfam call on Ireland to drop opposition to public country-by-country reporting: Naomi O’Leary / The Irish Times→

February 24, 2021

Americas

Laurence H. Tribe will represent Coca-Cola in transfer pricing dispute with the US IRS: The Coca Cola Company→

February 24, 2021

Europe

Spain to scrutinize taxpayers’ transfer pricing positions in 2021

February 24, 2021

Pilar Barriguete and Edland Graci, Duff & Phelps, Spain, discuss the Spanish government’s priorities for tax enforcement, set out in a January 19 announcement . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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