In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry experts presented key issues on March 13 and 14, 2019. ... - Continue reading
In early July, the Israeli Tax Authority (ITA) issued an update to Form 1385 - "Declaration of International Transaction.” ... - Continue reading
The US IRS will once again examine allocations between group members of employee stock-based compensation in cost-sharing arrangements for transfer pricing purposes. ... - Continue reading
Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading
The Hong Kong Inland Revenue Department (IRD) on 19 July published Departmental Interpretation and Practice Notes (DIPNs) Nos. 58, 59, and 60, and an updated version of DIPN No. 28. ... - Continue reading
A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading
Intangibles are key sources of differentiation for businesses and typically, they help drive revenue, manage cost or both. As a result, many businesses make significant investments in developing, enhancing, maintaining and protecting unique and valuable intangibles to help drive their businesses. ... - Continue reading
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
The Directorate General of GST Intelligence (DGGSTI), an arm of the indirect tax administration, has unearthed a racket involving 90 firms which issue fake invoices to errant companies for tax evasion, the agency said on Friday. ... - Continue reading
G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. ... - Continue reading
The Inter-American Center of Tax Administrations (CIAT), on July 15, released comprehensive and detailed proposals aimed at preventing abusive transfer pricing in low-income countries and in countries on the path to development. ... - Continue reading
Hot topics for discussion at the conference included taxation of the digital economy, approaches for "hard to value intangibles", the adoption of technology within the tax department, and lessons learned from country-by-country reporting. ... - Continue reading
TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading
Tax authority of Australia takes measures on tax issues ... - Continue reading
New tax legislation for India's 2019 Budget ... - Continue reading
Duff & Phelps' Transfer Pricing Alliance Partner, TP EQuilibrium AustralAsia, contributed their insights, expertise and perspectives on this new development. ... - Continue reading
Guide to Cash Pools And Transfer Pricing ... - Continue reading
Transfer pricing positions to be reviewed by IRS ... - Continue reading
The length of time taken to settle tax investigations into large businesses has increased by 10% to a record 43 months as of March 2019 ... - Continue reading
National Board of Revenue is building up profiles of the multinational companies operating in the country for the purpose of conducting audits on the MNCs’ accounts to prevent tax evasion through misuse of transfer pricing system. Transfer Pricing Cell (TPC) of NBR is also conducting risk assessment of the companies’… – Continue reading
It has been over a year since the Tax Cuts and Jobs Act (“TCJA”) was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 (“the Section 482 regulations”) have remained relatively unchanged since 1986. Nonetheless, multinational corporations doing business within the United… – Continue reading
New guidelines to tackle profit shifting and transfer pricing ... - Continue reading
On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill). This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations… – Continue reading
After consulting with professionals in the Mediterranean island’s service sector the Finance Ministry is drafting a bill on Transfer Pricing guidelines. The Transfer Pricing regime concerns tax treatment of intra-group financing transactions. The draft bill aims to put an end to the over-pricing of intra-group invoices so that any low… – Continue reading
Finance minister AHM Mustafa Kamal has said that the foreign companies will be required to have local partners for doing business in Bangladesh as the government wants to bring them under the tax net. ‘No foreign company can do business alone here any longer,’ he told reporters on Thursday after… – Continue reading
Globalisation of the economy has resulted in a shift in the way Singapore corporations operate – from local country-specific business models, to global integrated supply chains which centralise functions at a regional or global level. Singapore, in particular is a popular location to house regional and global operations, due to… – Continue reading
The winners of International Tax Review’s 2019 Asia Tax Awards have been announced with Ernst & Young named Tax Firm of the Year. After three consecutive crowns in the Asia Tax Awards’ Tax Firm of the Year category, KPMG has this year been bumped from the podium by fellow Big… – Continue reading
As per the agreement, it is intended to provide relevant and reliable information to perform an efficient and robust transfer pricing risk assessment analysis. Aimed at providing relief to subsidiaries of US multinationals and ensuring a check on cross-border tax evasion, India has notified the inter-governmental agreement with the United… – Continue reading
The income tax department is said to have adopted at least six different ‘out of the ordinary’ methods to recover tax dues The income tax department this year also used a rare provision to collect dues directly from a company’s bank accounts Mumbai: Every year in March, the income tax… – Continue reading
Supreme Court verdict a slap in the face for SKAT A case that has been going on for almost ten years has now come to an end, and the outcome has not been favourable to Danish taxpayers. The SKAT tax authority took Microsoft to court because it felt the company… – Continue reading
Tax advisory revenue at professional services firms expanded 8.6 percent to $20.3 billion in 2017, and grew by around $5 billion in just the three years from 2014 to 2017, according to a new report. The report, from Source Global Research, found that the main tax advisory services around the… – Continue reading
Once the UAE fully implements the BEPS minimum standard, it will become a very good location, say tax experts The UAE’s position as an attractive destination for foreign investment will substantially improve once it fully implements minimum standards for base erosion and profit shifting (BEPS), tax analysts said on Saturday…. – Continue reading
The Federal Inland Revenue Service (FIRS) recently released the Income Tax (Transfer Pricing) Regulation 2018 (‘the Regulation’). The Regulation took effect from 12th March 2018 and replaces the Income Tax (Transfer Pricing) Regulations, 2012. The Regulation sets out the legal framework for the application of the arm’s length principle to… – Continue reading
The misconceptions about transfer pricing being a tax avoidance or violation in Vietnam are creating challenges for multinational enterprises, said Adam Sitkoff, executive director of the American Chamber of Commerce in Vietnam (Amcham). In his opening speech at a workshop held to gain clarity on the changing world of transfer pricing,… – Continue reading
Many taxpayers in China have had questions about how the government would change the individual income tax (IIT) law since the amendment was passed earlier this year. Recently, however, the tax authorities released a draft of the amendment’s implementation rules and measures for comment. While the draft implementation rules and… – Continue reading
Caerphilly-based credit referencing company Creditsafe has paid Her Majesty’s Revenue and Customs almost £1 million after it was served with a ‘Diverted Profits Tax’ charge. Registered as Creditsafe Business Solutions, the company, based at Caerphilly Business Park, sells business data for credit check purposes and other uses. According to full… – Continue reading
As part of the British Virgin Islands’ (“BVI”) ongoing commitment to international tax transparency pursuant to the Common Reporting Standard (“CRS”), the BVI Mutual Legal Assistance (Tax Matters) Act, 2003 has been amended by the BVI Mutual Legal Assistance (Tax Matters) (Amendment) Act, 2018 (the “Amendment Act”). The Amendment Act… – Continue reading
The Federal Government is seeking assistance from the International Monetary Fund (IMF) on modalities for improving tax collection, especially from the International Oil Companies (IOCs), Finance Minister Zainab Ahmed, has said. She told reporters on the sidelines of the ongoing 2018 International Monetary Fund (IMF)/World Bank Group Meetings, in Bali,… – Continue reading
The more detailed scrutiny of the tax affairs of multinationals, large corporations and wealthy individuals, made possible by the formation of the Tax Avoidance Taskforce, has collected $5.6 billion in extra tax in just two years. Deputy Commissioner Mark Konza said “the $679.9 million the Government funded the ATO for… – Continue reading
The General Department of Taxation has been reviewing press information about foreign firms continuously reporting loss to have inspection plan in the upcoming time. The general department has required tax agencies to focus on inspection over these companies. According to articles published on Sai Gon Giai Phong Newspaper in May… – Continue reading
Viet Nam News HÀ NỘI —Vietnam will institute new policies designed to attract foreign direct investment (FDI) by boosting the development of local companies and setting up value chains driven by advanced technologies. FDI has been a major factor in Vietnam’s rapid socio-economic development; however, some key metrics remain below… – Continue reading
Transfer pricing cell of National Board of Revenue has remained nearly dysfunctional since its formation five years back due mainly to lack of logistic support, expert and dedicated manpower and propelling initiative of the tax authorities. The cell even could not conduct audit on any statement of international transactions of… – Continue reading
VietNamNet Bridge – Nearly 38 percent of foreign invested enterprises (FIEs) reported losses in 2017, a significant decrease from the 50 percent seen in previous years. However, transfer pricing by FIEs remains a headache for management agencies. Do Thien Anh Tuan of Fulbright University said that enterprises that most regularly… – Continue reading
Federal Inland Revenue Service has published Nigeria’s revised Transfer Pricing Regulations (NTPR). The NTPR is effective for basis periods commencing after 12 March 2018 and incorporates BEPS outcomes and suggestions from The African Tax Administration Forum. The NTPR includes significant penalties for non-compliance (a) failure to file TP declaration =… – Continue reading
The Internal Revenue Service is making some adjustments to its Compliance Assurance Process, a program aimed at large corporate taxpayers that involves cooperating with the IRS before any audits. As part of the proposed changes, the IRS said Monday it will shift the start of the application period to Oct…. – Continue reading
Last week, Medtronic Plc suffered a legal setback in its bid to avoid a $1.4 billion U.S. tax bill — a ruling that may have costly implications for other multinationals battling the Internal Revenue Service over the use of overseas payments to lower their taxes. Companies including Facebook Inc. and… – Continue reading
News that the government may bring in an ‘Amazon tax’ to help “rebalance the playing field” between physical and online retailers has been welcomed by booksellers. After department store retailer House of Fraser became the latest high street chain to go into administration on Friday (10th August) Philip Hammond said… – Continue reading
Most multinational corporations (MNCs) charge their subsidiaries for services like human resources (HR) or information technology support. The subsidiary’s payment for these services is classed as intra-group service fees when they are made within same enterprise group. Because some businesses use this method to avoid tax and shift profits, tax… – Continue reading
