The US Customs and Border Protection (US CBP) published a Notice on May 16 revoking a Headquarters Ruling, HRL 54764 (November 8, 2001). The revocation should make it easier for companies importing products purchased from a related party to navigate the potentially conflicting rules and procedures for complying with US transfer pricing rules, while properly reporting the dutiable value of property imported from a related party.
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The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance