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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

  • World Tax Authority: Taking harmonisation to the next level

    August 29, 2014

    Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Authority (WTA)? Would it take tax harmonisation to the next level or, like the Europe-wide language of Esperanto, is this attempt at harmonisation doomed to fail? Matthew Gilleard analyses what has motivated discussion of such a concept and looks at the barriers to implementation.

  • Going the extra mile – when finance and IT suddenly awoke

    August 29, 2014

    In the July/August issue, Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group, took a retrapolative look at the country-by-country reporting standard five years into its implementation. In part two, he looks at how different functions within a multinational company are interacting with the tax team to manage reporting obligations.

  • The IMF and international tax

    August 29, 2014

    David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation.

  • Amazon struggles to resolve $1.5 billion dispute with IRS

    August 06, 2014

    The international e-commerce company, Amazon, has failed to resolve elements of its transfer pricing dispute with the Internal Revenue Service (IRS). The case revolves around the retailer’s use of a European subsidiary to reduce its tax bill which, if it loses, could cost the company billions.

  • Inversions - special focus

    August 04, 2014

    Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for US companies, particularly those in the highly-mobile pharmaceuticals sector. Whatever the motivation, inversions are in vogue. ITR’s special report looks at the knock-on impacts of the current wave of inversions, including shareholder pressure to consider an option they see their rivals pursuing and the possible inflammation of the tax morality debate in the US. We also bring you exclusive insight as to why Danaher is not looking to invert.

  • BEPS and CbCR: A retrapolation five years on

    July 01, 2014

    One of the most contentious issues being considered as part of the OECD’s base erosion and profit shifting (BEPS) project is the notion of country-by-country reporting (CbCR) of multinational companies’ tax information. Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group in Germany, steps forward in time to take a hypothetical look at the reporting standard five years after implementation.

  • European Tax Awards 2014

    July 01, 2014

    The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21.

  • What chief financial officers need from their tax directors

    July 01, 2014

    Jean-Louis Huchant, a former chief financial officer in France, explains what information and support a CFO requires from a tax director to ensure that tax considerations are taken into account, though do not dominate, business decisions.

  • Transfer pricing risk management: A case for APAs

    July 01, 2014

    Victor Adegite of KPMG Nigeria looks at the advance pricing agreement (APA) option as a tool taxpayers can use as part of their transfer pricing risk management, highlighting the benefits of different types of APA and looking at how APA programmes operate in other jurisdictions.

  • Marzen Aluminum ruling based on structuring rather than pricing

    July 01, 2014

    In the first decision of its kind, the Tax Court of Canada ruled that while Marzen Artistic Aluminum provided sales and marketing staff to Starline International at arm's-length, the documentation provided was insufficient.

International Tax Review Profile

RT @PearseTrust: "Is it time to scrap the #FTT?" http://t.co/1EeSaUuCHI by @IntlTaxReview #Tax

Aug 29 2014 01:39 ·  reply ·  retweet ·  favourite
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RT @TPWeek: Inversion whopper anyone? #funfridays #transferpricing #taxinversions #BurgerKing #TimHortons http://t.co/GsG4lzlc2E

Aug 29 2014 10:45 ·  reply ·  retweet ·  favourite
International Tax Review Profile

GMAC judgement due on Wednesday @EUCourtPress Here's #UK Tribunal's request for prelim ruling http://t.co/6khzFBoVkL #VATrepayment

Aug 29 2014 10:01 ·  reply ·  retweet ·  favourite
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RT @taxmOuth: TaxProse Daily Tax News is out! http://t.co/e5mLQcHw0x Stories via @IntlTaxReview @YourVoiceAtIRS Thanks for the mention!

Aug 29 2014 09:46 ·  reply ·  retweet ·  favourite
International Tax Review Profile

#ff @APMTerminals @iaincampbell07 @arungiri @GlobalTaxAdvice

Aug 29 2014 09:45 ·  reply ·  retweet ·  favourite

Which possible outcome of the G20 / OECD BEPS project would carry the biggest fear for your company?