TP WEEK NEWS BRIEFS For April 25, 2016
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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 & bottom lb ros

More from across our site

Mazars needs to do all it can to capitalise on TP as a growth area, ex-Deloitte TP director Jeremy Brown has told ITR
Sanjay Sanghvi and Raghav Bajaj of Khaitan & Co provide a practical guide for foreign investors looking to capitalise on Indian’s investment potential
The newly launched Tax Responsibility and Transparency Index will assess the ethicality of companies’ tax practices against global standards and regulations
The reported warning follows EY accumulating extra debt to deal with the costs of its failed Project Everest
Law firms that pay close attention to their client relationships are more likely to win repeat work, according to a survey of nearly 29,000 in-house counsel
Paul Griggs, the firm’s inbound US senior partner, will reverse a move by the incumbent leader; in other news, RSM has announced its new CEO
The EMEA research period is open until May 31
Luis Coronado suggests companies should embrace technology to assist with TP data reporting, as the ‘big four’ firm unveils a TP survey of over 1,000 professionals
The proposed matrix will help revenue officers track intra-company transactions from multinationals
The full list of finalists has been revealed and the winners will be presented on June 20 at the Metropolitan Club in New York
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