US APMA stats for 2013 show promise but proposals have negative undertones New proposals for APA and MAP applications, released during the last quarter of 2013, reflect changes in the advance pricing and mutual agreement programme’s (APMA) structure. By Sophie Harding April 03 2014
BEPS and its interraction between TP and indirect tax The potential impact of the OECD’s BEPS project on indirect tax is a topic that has been overshadowed, with discussions focusing on intangibles and country-by-country Reporting (CBCR); however, it remains... By Sophie Harding April 02 2014
Why tax market doubts country-by-country reporting The OECD issued a revised draft of chapter V of the OECD guidelines on documentation in January, which placed emphasis on transfer pricing enquiry and risk assessment. By Sophie Harding April 01 2014
OECD announces changes to CBCR guidelines At a recent conference in Paris, the OECD’s Joe Andrus, director of transfer pricing, discussed the results of Working Party 6 deliberations and announced the alterations that will be made... By Sophie Harding April 01 2014
APA trends in emerging markets As business operations in emerging markets increase, more countries are implementing and developing advance pricing agreement (APA) regimes. China, India and Turkey represent three different approaches but indicate that APAs... By Sophie Harding March 27 2014
Indian Special Bench questions choice of comparables in Maersk’s TP report An Indian Special Bench ruling has emphasised the importance of functional comparability in transfer pricing (TP) reports and concluded that high margin comparables cannot be excluded. By Sophie Harding March 24 2014
New PE ruling in Denmark reawakens concerns for foreign investors The Danish National Tax Board recently issued a ruling which changed a limited partnership to the status of permanent establishment (PE), suggesting a move towards broader categorisation of what constitutes... By Sophie Harding March 20 2014
European law used in Turkish transfer pricing case Turkey recently implemented European Court of Human Rights (ECHR) law in a transfer pricing case, signalling a pioneering move towards developments in taxpayers’ rights. By Sophie Harding March 19 2014
Why French taxpayers must start litigation to benefit from deferral of payment French taxpayers must pay any additional tax assessed by the authorities in advance of a mutual agreement procedure, according to the country’s 2014 Finance Act (No 2013-1278). By Sophie Harding March 18 2014
