Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches
Guidance on transfer pricing transactions during the unprecedented crisis. ... - Continue reading
Category: Transfer pricing
Italy’s Supreme Court rules on VAT treatment of intercompany management fees
Highlights on a recent court case in Italy regarding transfer pricing. ... - Continue reading
German finance ministry clarifies transfer pricing proposal
"No price-setting approach", confirms the German Finance Ministry. ... - Continue reading
Ireland transfer guidance addresses claims for unilateral tax relief
Lights upon Ireland's unilateral tax relief in relation to the double taxation agreement. ... - Continue reading
OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance
Disagreement registered around the 'Pillar One' of the OECD. ... - Continue reading
EU Commission to investigate whether Netherlands granted IKEA subsidiary State aid by approving tax deductions
The European Commission to investigate into Inter IKEA systems' tax treatment for a possible breach of EU State Aid rules. ... - Continue reading
New Poland transfer pricing risk assessment tool released in interactive format
Poland launches a new transfer pricing risk assessment tool and it's an interactive version. ... - Continue reading
Finland transfer pricing rules analyzed in landmark court rulings
This article focuses on two tax cases revolving around transfer pricing and their respective treatments. ... - Continue reading
COVID-19 and the future of Pillar one
2020 started with a focus on reformed tax laws concerning transfer pricing and the implementation of Pillar one from the OECD. This article delves further into the matter to bring more clarifications. ... - Continue reading
New South Korea transfer pricing and diverted profits tax laws enter into effect
A few information on amended tax laws for South Korea as from 2020. ... - Continue reading
Denmark extends all filing deadlines, including those for transfer pricing documentation
Extension until 1st September 2020 for deadlines, and it won't even require an application. ... - Continue reading
Nigeria’s Tax Appeal Tribunal decides Prime Plastichem transfer pricing case
A first transfer pricing case in Nigeria offers a glimpse of the treatment of the latter. ... - Continue reading
Poland issues controversial transfer pricing risk assessment rules
New transfer pricing laws issued in Poland might not be too pleasant to multinationals' ears. Read on to know more. ... - Continue reading
India Budget 2020: The key takeaways
Here are some important tax proposals for India's 2020 Budget. ... - Continue reading
The final OECD transfer pricing guidelines for financial transactions: what has changed?
Amendments to transfer pricing laws have been disclosed on 11 February 2020. ... - Continue reading
Spain to scrutinize taxpayers’ transfer pricing positions
Spain focuses on transfer pricing. ... - Continue reading
United States: The OECD Unified Approach Marches (Stumbles?) Forward
The OECD Secretariat proposed the Unified Approach in October 2019 to address the tax challenges arising from the digitalization of the economy. ... - Continue reading
Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere
The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading
Malta: Tax Transparency For Tax Advisors: The Mandatory Disclosure Rules – No More Hiding
The main aim remains linked to curbing tax evasion and avoidance through capturing aggressive tax planning schemes.
... - Continue readingCountries launch review of country-by-country reporting framework for multinational groups
An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.... - Continue reading
Puerto Rico changes income tax law for intercompany charges
Puerto Rico has amended its income tax rules to allow taxpayers to fully deduct intercompany expenses if taxpayers file a transfer pricing study with their income tax return, due April 15, 2020, if not extended. ... - Continue reading
Denmark court applies broad interpretation of transfer pricing law
More on the new Danish transfer pricing legislation. ... - Continue reading
Vietnam issues Draft Pronouncement on Tax Administration, Transfer Pricing, Minimum Basic Wage and Personal Income Tax
The Vietnam Ministry of Finance has issued the draft pronouncement amending certain tax rulings. Some of the main aspects of the draft include: ... - Continue reading
Heineken Vietnam pays $39.7 mln in back taxes, fines
Heineken Vietnam Brewery has paid VND917.2 billion ($39.7 million) in back taxes and fines for a 2018 transaction. ... - Continue reading
Bulgaria: Introduction Of Mandatory Transfer Pricing Rules In Bulgaria
New law hits taxpayers. ... - Continue reading
Singapore: Singapore’s New Transfer Pricing Requirements
What you need to know if you conduct business in Singapore. ... - Continue reading
Transfer Pricing Cell to put 921 foreign companies under scanner
The National Board of Revenue (NBR) to scrutinise some 921 foreign companies operating in Bangladesh. ... - Continue reading
ATO data reveals one third of large companies pay no tax
Of 2,214 entities covered by the Australian Taxation Office (ATO) data for 2017-18, 710 did not pay any tax. ... - Continue reading
Nigeria: 15 Insights On Transfer Pricing In Nigeria
Clarifications on the role of transfer pricing in Nigeria ... - Continue reading
Australia: Simplified Transfer Pricing Record Keeping Options In Australia
Australian entities that meet certain requirements can shortcut the usual lengthy and expensive transfer pricing record keeping process. ... - Continue reading
Estimating reliable transfer pricing profit indicators requires use of all available data
Consider two aspects of statistical reliability principles. First, reliability can be measured by the ratio of the selected variable estimate divided by its standard error. ... - Continue reading
OECD director, tax experts, explore proposed “unified approach to pillar one” for taxing multinational groups
Highlights of the “unified approach to pillar one” proposal ... - Continue reading
First Look: Ireland publishes finance bill with international tax and transfer pricing changes
The Irish government today published Finance Bill 2019, which contains legislation to enact tax measures taking effect primarily from January 1, 2020. ... - Continue reading
India: Rules To ‘Secondary Adjustment’ Rationalized And Clarified
The concept of 'Secondary Adjustment' was introduced in Finance Act 2017 by introducing new Section 92CE in the Indian Income Tax Act (the Act) to align transfer pricing provisions with international best practices. ... - Continue reading
Nigeria: FIRS To Deploy E-Filing Platform For Transfer Pricing Related Returns
In 2017, the Federal Inland Revenue Service (FIRS) announced the introduction of six (6) new electronic services. ... - Continue reading
Ireland Budget 2020 released
On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading
Ireland Transfer Pricing Feedback Statement Explained
The Irish Government recently published a Transfer Pricing Rules Feedback Statement which is explained in this article. ... - Continue reading
The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty.
In late September, the EU General Court released its decisions in two long-awaited state aid appeals: Fiat (cases T-755/15 Luxembourg v Commission and T-759/15 Fiat Chrysler Finance Europe v Commission) and Starbucks (cases T-760/15 Netherlands v. Commission and T-636/16 Starbucks and Starbucks Manufacturing Emea v. Commission). ... - Continue reading
Argentina issues burdensome draft transfer pricing guidance for public comment
Argentina’s tax authority on October 2 launched a public consultation on proposed guidance that includes significant and burdensome changes to the transfer pricing requirements that local taxpayers must comply with. ... - Continue reading
Paraguay introduces transfer pricing rules
Paraguay, on September 13, enacted special regulations providing for the transfer pricing analysis of intercompany transactions. ... - Continue reading
Draft “toolkit” aims to help developing countries with transfer pricing documentation
The Platform for Collaboration on Tax – a joint initiative of the International Monetary Fund, OECD, United Nations, and World Bank Group – on September 27 released a draft “toolkit” aimed at helping developing nations design transfer pricing documentation rules. ... - Continue reading
Australian tax office advises on transfer pricing for offshore drilling
The Australian Taxation Office (ATO) on September 27 set out its approach to analyzing transfer pricing issues associated with the use in Australian waters of non-resident owned mobile offshore drilling units such as drill-ships, drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs), pipe-laying vessels, and heavy-lift vessels. ... - Continue reading
CITIRA set to replace outdated tax scheme
Finally, the outdated and “dysfunctional” tax regime based on gross income earned is now about to end with the expected enactment into law of the new Corporate Income Tax and Incentives Rationalization Act (CITIRA), which the House recently passed with a vote of 170 versus eight against and six abstentions. … – Continue reading
Denmark tax bill clarifies timing rules for transfer pricing documentation
Denmark’s Ministry of Taxation on 12 September published a draft bill proposing a number of changes to Denmark’s international tax provisions including a requirement to submit transfer pricing documentation together with the corporate income tax return. ... - Continue reading
Taxation of the digital economy, future of debt, and other OECD updates during the IFA Congress 2019 in London
The IFA Congress 2019, held 8-12 September in London, brought together leading international tax and transfer pricing experts from around the world. ... - Continue reading
France joins ICAP pilot to jointly assess MNE tax positions
France has joined the International Compliance Assurance Programme (ICAP) pilot program, the OECD announced September 16, bringing the total number of tax administrations participating to 18. ... - Continue reading
EU Commission’s tax policy 2019 – 2024: What can we expect?
The start of a new European Commission also means setting new political priorities in the EU tax field. ... - Continue reading
Unresolved cross-border tax disputes continue to rise, OECD stats show
Despite OECD efforts to encourage countries to more swiftly and effectively resolve of cross-border tax disputes, overall mutual agreement proceedure (MAP) inventory continues to increase, OECD statistics released today revealed. ... - Continue reading
Saint Amans provides update on digital tax reform effort
The preliminary results of an impact assessment reveal that proposals advanced in an OECD-led effort to update the global rules for taxing digital businesses would not create large changes to countries’ existing taxing rights, Pascal Saint-Amans, OECD Director of the Centre for Tax Policy and Administration, said September 11. ... - Continue reading
