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Transfer Pricing

For more transfer pricing news and analysis, please visit ITR’s sister publication, TP Week.

TP Week provides an outstanding and market-leading source of up to the minute information and comment on transfer pricing issues.  So whether you are a tax director in industry, a tax adviser, government representative or transfer pricing specialist, all the intelligence, comment and analysis you need can be found at www.tpweek.com

  • BEPS implementation in the US - Now comes the hard part

    June 30, 2015

    While the OECD has political backing and momentum behind it, the organisation has no binding authority to implement legislation, so the engagement of key jurisdictions including the US will be central to the project's ultimate success. Ryan Dudley, partner at Friedman, explains why the hard yards still lie ahead.

  • Hatch and Ryan voice US BEPS concerns; urge Lew not to forget Congress in discussions

    June 10, 2015

    The Republicans leading the US Congress’ two tax-writing committees have called on Jacob Lew, Treasury Secretary, to “remain engaged with Congress” as proposals related to the OECD base erosion and profit shifting (BEPS) project continue to be developed.

  • ITR launches app!

    June 01, 2015

    The International Tax Review app is now available! International Tax Review subscribers can now download the ITR app, giving them full access to the latest ITR articles while they are on the go.

  • Businesses report difficulties in obtaining APAs with China

    May 28, 2015

    Though China has had an advance pricing agreement (APA) programme for nearly a decade, some businesses report that obtaining APAs in China is challenging due to a lack of manpower at the State Administration of Taxation’s (SAT) transfer pricing team.

  • The Brockman brief: UK diverted profits tax: The extrapolation effect

    May 27, 2015

    The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?

  • BEPS: Improving data, economic analysis and measurement

    May 27, 2015

    It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.

  • BHP Billiton faces $432 million tax bill in Australia

    May 06, 2015

    The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a marketing affiliate in Singapore. The company’s Singapore tax bill is also being questioned under Australia’s controlled foreign company (CFC) rules, which require a minimum payment of tax.

  • How hundreds of multinationals are preparing for BEPS legislation and what you can do

    April 30, 2015

    BEPS is a significant landmark for multinational companies and international revenue organisations. It will mean big changes to companies’ tax and transfer pricing operations. And, while no one knows specifically how the new measure will impact them, taxpayers are trying to prepare.

  • The Brockman brief: Timing symmetry is shattered: CbCR and TP documentation

    April 28, 2015

    May’s instalment of his column sees Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, look at the problems that may arise for taxpayers given the timing differences applicable for different documentation and reporting requirements, and what options are available for reconciling these.

  • Tax planners’ task tougher than ever

    April 28, 2015

    Failing to plan is planning to fail. We are all familiar with the phrase. But practising what one preaches in this regard has never been more important for corporate taxpayers.

International Tax Review Profile

RT @expertmile: #tax Justice AP Shah panel holds meeting with tax department on MAT issue http://t.co/KT4o0unXgu

Jul 7 2015 01:34 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Need to discuss about assumptions about value that are ingrained in status quo #taxpanel #DiarmidOSullivan @ActionAid

Jul 7 2015 01:34 ·  reply ·  retweet ·  favourite
International Tax Review Profile

BelemaOfuoforibo: Govts shouldn't hide behind morality argument with poorly drafted law #taxpanel

Jul 7 2015 01:06 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Need for proper debate on what is fair / unfair #tax competition #taxpanel #ChrisMorgan @ActionAid @kpmguk

Jul 7 2015 12:57 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Race to bottom on #tax rates is exaggerated #taxpanel #ChrisMorgan @kpmguk

Jul 7 2015 12:54 ·  reply ·  retweet ·  favourite
International Correspondents

After the Irish budget, what would make you more likely to put more substance into Ireland?