Transfer Pricing

Americas

BVI notice addresses country-by-country reporting schema update and deadlines: Virgin Islands International Tax Authority→

January 11, 2021

Americas

The origins of transfer pricing’s comparable profits method

January 6, 2021

Ednaldo Silva, Director, RoyaltyStat, Bethesda, Md., discusses the reasons why US IRS transfer pricing officials adopted the comparable profits method . . .

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

January 6, 2021

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Europe

Dutch informal capital scheme should be investigated for illegal state aid, professor says: Jan Vleggeert / SSRN→

January 5, 2021

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

Asia-Pacific

Singapore ruling concludes that corporation and three foreign shareholders are not related parties for transfer pricing purposes: Inland Revenue Authority of Singapore→

January 4, 2021

Americas

US, Turkey negotiating exchange of MNE country-by-country reports

January 4, 2021

The competent authorities of the US and Turkey have commenced negotiations for the exchange country-by-country reports . . .

Europe

German transfer pricing amendments shift burden of proof, reveal climate of distrust

December 28, 2020

Oliver Treidler, CEO, TP&C GmbH, Berlin, discusses revised German Federal Ministry of Finance transfer pricing guidelines, released December 3, that increase taxpayer compliance burdens and grant greater powers to the tax authority . . .

Asia-Pacific

New Zealand hits Oracle with NZ 20.3M (USD 14.4M) in transfer pricing assessments: Rob O’Neill / New Zealand Reseller News→

December 23, 2020

Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

December 21, 2020

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

Americas

Peru tax authority requires multinational groups to file country-by-country reports

December 21, 2020

Yasser Zola, Transfer Pricing Manager, BaseFirma Perú, Lima, discusses Peru tax authority guidance, published on December 2 and December 16, addressing multinational groups’ obligation to file country-by-country reports . . .

Africa

Benin introduces transfer pricing private ruling procedure

December 21, 2020

Moïse Gnakouri, a Doctoral researcher at the Catholic University of Louvain, Brussels, Belgium, discusses a new law adopted by the Benin parliament on December 8 that allows multinationals to apply for transfer pricing rulings . . .

Americas

Cayman Islands amends country-by-country reporting guidance and schema

December 21, 2020

The Cayman Islands on December 17 issued amended country-by-country reporting . . .

Asia-Pacific

Australia updates transfer pricing guidance on simplified record-keeping options: Australian Taxation Office→

December 17, 2020

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

December 16, 2020

The OECD today released more than 250 comment letters in response to a request for public . . .

Europe

German transfer pricing guidance addresses taxpayers’ obligation to cooperate with tax office

December 16, 2020

Konstantin Sakuth of Linklaters LLP, Munich, discusses December 3 transfer pricing guidance issued by Germany’s Federal Ministry of Finance that addresses a multinational group taxpayer’s obligation to cooperate with the tax authorities concerning income allocation . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

December 15, 2020

Americas

Taxing multinational group excess profit in the US, UK, and Belgium

December 15, 2020

Dr. J. Harold McClure, New York, notes the EU Advocate General’s recent opinion concerning Belgium’s excess profits tax and discusses approaches to the taxation of these profits in the US, UK, and Belgium . . .

Europe

Blackrock’s transfer pricing battle with the UK: unexplored intercompany financing issues

December 11, 2020

Dr. J. Harold McClure, a New York City economist, discusses intercompany loan pricing issues revealed in a November 3 UK Tribunal decision favoring the UK affiliate of investment management group, Blackrock . . .

Africa

Transactional profit indicators for the TNMM are not viable

December 9, 2020

Dr. Ednaldo Silva, Founder, RoyaltyStat, Washington DC area, explains why it is not possible to determine “transactional” profit indicators for the transactional net margin method (TNMM) in transfer pricing analysis . . .

Africa

ICAP pilot for transfer pricing audits to be made permanent, OECD says

December 9, 2020

The OECD Forum on Tax Administration (FTA), comprised of 53 member country tax administrations, has . . .

Asia-Pacific

Glencore’s Australia transfer pricing litigation – the economic considerations

December 9, 2020

Dr. J. Harold McClure, New York City, provides a detailed analysis of Glencore’s long-running transfer pricing dispute with Australia over the pricing of copper from the Cobar mines, most recently addressed by the Federal Court of Australia in a November 6 decision . . .

Europe

Italy updates transfer pricing regulations

December 7, 2020

Angela Valente, Diego Conte, and Alessandro Foti of De Berti Jacchia, Milano, discuss Italian transfer pricing documentation regulations issued on November 23 that, among other things, address low-value-added services, new signature requirements, and the definition of small and medium-sized entities . . .

Americas

US and Germany again agree to exchange country-by-country reports on large multinationals

December 4, 2020

The competent authorities of the US and Germany have issued a joint statement, agreeing . . .

Digital Economy

UN tax committee releases official report on outcome of 21st session: Committee of Experts on International Cooperation in Tax Matters→

December 2, 2020

Asia-Pacific

Australia defers due date for December country-by-country report filing: Australian Taxation Office→

December 1, 2020

Asia-Pacific

Thailand clarifies transfer pricing rules for using internal and external comparables

December 1, 2020

Andrew Jackomos, Co-Managing Partner, and Rohit Sharma, Principal, Transfer Pricing, at HLB Thailand, discuss a November 6 Thailand regulation prescribing the approach that Thai tax officers should take when analyzing and adjusting the pricing of transactions between related parties . . .

Europe

Ireland updates tax manual to reflect updates to country-by-country reporting user guide and XML schema: Irish Tax and Customs→

November 30, 2020

Africa

Shell releases 2019 country-by-country report disclosing revenue, profits, tax paid in 98 countries: Shell.com→

November 30, 2020

Inclusive Framework on BEPS

Professor concludes that the OECD pillar one & two proposals would be significant reform that responds to identified flaws in the international tax system: Craig Elliffe / SSRN→

November 30, 2020

Asia-Pacific

Taiwan clarifies APA request procedures when taxpayer changes its business address after application submitted: Taiwan Ministry of Finance→

November 30, 2020

Americas

US and Monaco agree to exchange country-by-country tax reports on large multinationals

November 30, 2020

The US IRS today announced that the US and Monaco have agreed . . .

Americas

The US and Mexico’s transfer pricing approach for maquiladoras

November 30, 2020

Dr. J. Harold McClure, New York City, notes that the US’s announcement on November 16 that the US and Mexico have again agreed to renew their transfer pricing framework for US multinational enterprises that have maquiladora operations and discusses the appropriate arm’s length transfer pricing policies for maquiladoras . . .

Asia-Pacific

Australia should change transfer pricing laws if Commissioner’s appeal of Glencore case is unsuccessful, former ATO deputy commissioner says: Jim Killaly / Tax and Transfer Policy Institute→

November 25, 2020

Americas

A proposed transfer pricing safe harbor for US retailers

November 24, 2020

Dr. Ednaldo Silva of RoyaltyStat, Bethesda, MD, proposes that US state tax authorities allow US retailers to apply a safe harbor that defines the arm’s length operating profit markup based upon a formula . . .

Americas

US IRS prevails in Coca-Cola transfer pricing dispute over intercompany royalties

November 23, 2020

Dr. J. Harold McClure, a New York City economist, discusses the US Tax Court’s November 18 ruling in a transfer pricing dispute between the IRS and Coca-Cola which considered the appropriate evaluation of intercompany royalties . . .

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Africa

OECD proposes revised “minimum standards” for nations on cross-border tax dispute resolution

November 19, 2020

The OECD Secretariat has requested public feedback on proposals designed to strengthen the Action 14 minimum standards on cross-border tax dispute . . .

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin