TP WEEK NEWS BRIEFS For April 25, 2016

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

TP WEEK NEWS BRIEFS For April 25, 2016

Michelle Johnson

The latest headline news from Transfer Pricing Week. TP News Briefs include: the impact of US Treasury plans for earnings stripping on foreign MNEs; Australian deal to fast-track corporate tax cases, Czech Transfer Pricing Inspections; OECD to focus on BEPS; and US IRS meeting on new CbCR rules.



US Treasury plans for earnings stripping are troubling news for foreign-headquartered MNEs

   April 25 - The US Treasury’s plan to implement new rules on ‘earnings stripping’ will cause problems for foreign multinationals, including increased costs and limitations with debt leveraging, tax advisors warn. The proposed regulations could affect almost any company with transactions between members of an ‘expanded group’ that are intended to be characterised as debt for US federal tax purposes, Michelle Johnson of Duff & Phelps (pictured) told TP Week.


US Internal Revenue Service to examine new CbCR rules in May 

   April 25 – New US regulations requiring annual country-by-country reporting (CbCR) for US-parented MNEs (REG– 109822–15) will be the focus of the Internal Revenue Service public hearing in Washington, DC on May 13. The IRS plan would require the the report to be filed with the ultimate US parent entity’s income tax return for the taxable year. The US expects to finalise CbCR rules by July.

Czech Financial Administration performs 800 transfer pricing inspections

   April 25 – Czech tax officials at the Financial Administration (FA) performed 800 inspections focused on transfer pricing among related parties, resulting in additional income tax assessment in the amount of CZK 450 million ($18.7 million) in 2015, according to the Prague Daily Monitor news.  The success rate of transfer pricing inspections improved 31 per cent year on year. Andrej Babiš, Minister of Finance, said tax entities had started submitting additional tax returns on their own initiative to rectify their tax liabilities.  

Australia hopes to fast-track large corporate tax cases worth hundreds of millions of dollars

   April 25 - The Australian Tax Office (ATO) and Federal Court are close to a deal to fast-track “strategically important” corporate tax cases, Tax Commissioner Chris Jordan told a Senate corporate tax avoidance inquiry last week. Some cases are worth hundreds of millions in unpaid tax and have dragged on for years, according to the Sydney Morning Herald. The ATO believes the public is being short-changed, the Herald reported. Separately, Australia is leading an international group of tax inspectors planning cross-border investigations to target tax evaders.

OECD to focus on BEPS at the Beijing meeting 

   April 25 - The OECD will focus on international tax reform, including the impact of the post-BEPS environment on tax administrations, at the 10th Plenary meeting of the OECD Forum on Tax Administration in Beijing on May 11-13. The Forum brings together tax commissioners from 46 advanced tax administrations, including OECD and G20 countries. Taxpayers are invited to take the TP Week BEPS survey before the closing date April 26. Following the survey link here




more across site & shared bottom lb ros

More from across our site

Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks
The EU agreed new cooperative and investigative measures to tackle VAT fraud, while Hungary faced legal action and Lavez Coutinho expanded its indirect tax team
The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates
CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
Gift this article