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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: Improving data, economic analysis and measurement

    May 21, 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.

  • EU: Cross-border exchange of rulings - what's proposed?

    April 28, 2015

    Timothy Lyons QC and Kelly Stricklin-Coutinho of 39 Essex Chambers analyse recent transparency developments across Europe, focusing on the proposed requirement for EU member states to provide a quarterly report on all cross-border tax rulings and advance pricing arrangements.

  • DPT: Counterbalancing the UK's 'open for business' agenda?

    April 28, 2015

    The introduction of the UK's diverted profits tax (DPT) on April 1 2015 has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) it seemed intended to appease public anger at multinationals failing to pay their 'fair share' of tax. It has been roundly criticised for its breadth and complexity, for the speed with which it has been introduced, for the lack of public consultation and parliamentary scrutiny, and for pre-empting the multilateral response to tax avoidance of the G20/OECD BEPS Project. DLA Piper's Stephen Jones asks whether the DPT has created a cloud of uncertainty to cover the previous decade’s climate of reform favourable to global business.

  • Australia and UK want to go “further and faster” than the OECD on diverted profits action

    April 27, 2015

    The UK diverted profits tax (DPT) – dubbed the Google tax – has been in effect for almost a month, and Australia is looking at similar action to be included in its May 12 Budget speech, after signalling a desire to move “further and faster” than the OECD-led BEPS project. If other jurisdictions follow suit, this could drastically dilute the impact of multilateral efforts.

  • Danish GAAR threatens taxpayers with more uncertainty and aggression

    April 09, 2015

    The Danish government has introduced a Bill (L167) to implement a general anti-avoidance rule (GAAR) in the country for the first time, which would enable authorities to deny treaty benefits if obtaining those benefits was the sole or main purpose of an arrangement

  • PokerStars gaming website accused of €300 million tax evasion

    April 09, 2015

    The Italian tax authorities have accused online gaming websites PokerStars of tax evasion amounting to €300 million ($326 million).

International Tax Review Profile

20% CT v 25% DPT @George_Osborne policy clearly working whether one agrees with it or not @amazon #BEPS

May 23 2015 08:17 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @FT: #Amazon to book UK sales in Britain not Luxembourg, bringing revenues in 3rd biggest market in reach of taxman http://t.co/x8q6Pqe0

May 23 2015 08:07 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @DeloittePolska: RT @IntlTaxReview: Our choice for the Poland Transfer Pricing Firm of the Year prize is @DeloittePolska! #ITRawards2015

May 23 2015 07:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @GlobalTaxAdvice: #Taxand wins 5 @IntlTaxReview #European #Awards 2015! Discover more > http://t.co/b2RCGwE8rD http://t.co/HmKFvqeGtJ

May 23 2015 07:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @bakermckenzie: We are thrilled to have won Seven @IntlTaxReview Awards! http://t.co/4dJQnIR0D4

May 23 2015 07:59 ·  reply ·  retweet ·  favourite
International Correspondents

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