UN’s revised TP manual to go beyond OECD guidance Practical issues, arm’s-length practices, business models and value chains will be included in the UN’s revised transfer pricing manual for developing countries, co-coordinator Stig Sollund tells TP Week in an... By Lena Angvik July 12 2018
ATAD to hike intra-group financing costs for unprepared MNEs In-house tax professionals have told TP Week they expect the EU’s Anti-Tax Avoidance Directive to increase the cost of intra-group financing, but few have actually made structural changes in anticipation... By Lena Angvik July 10 2018
Christoph Kromer joins Warth & Klein Grant Thornton German firm Warth & Klein Grant Thornton has added Christoph Kromer to its partnership. Kromer, who will be based in Frankfurt am Main, brings with him his transfer pricing and... By Lena Angvik July 03 2018
MNEs pursue APAs to counter reputational risk Heads of tax are turning to bilateral advance pricing agreements to help prevent reputational risk from accusations of sweetheart tax deals between taxpayers and tax authorities. By Lena Angvik June 29 2018
Exclusive: ATO reveals transfer pricing on priority list Intellectual property transfers, related-party debt, offshore marketing hubs and hybrid mismatches are some of the areas the Australian Taxation Office is focusing on now, Deputy Commissioner Jeremy Hirschhorn tells TP... By Lena Angvik June 27 2018
Multinationals face transfer pricing risks by delaying ATAD assessment With only six months left before the wide-ranging EU’s Anti-Tax Avoidance Directive provisions enter into force, multinationals are advised to weigh compliance and controversy risks for cross-border tax structures across... By Lena Angvik June 22 2018
Duff & Phelps appoints European leader of global transfer pricing Ted Keen has joined Duff & Phelps as the European leader for the firm’s global transfer pricing practice. By Lena Angvik June 21 2018
Google India decision signals possible double taxation Google India is appealing a court decision that found payments made to Google Ireland should be classified as royalties. Digital companies operating in India fear the negative impact from the... By Lena Angvik June 20 2018
Bill Sample: Profit split should be last resort for digital economy The EU’s proposal for taxing the digital economy isn’t sitting well with American businesses. Bill Sample, former VP of tax at Microsoft and chair of the US Council for International... By Lena Angvik June 18 2018
CJEU decision allows for deviation from arm’s-length principle The Court of Justice of the European Union decided in the Hornbach-Baumarkt case that deviations from the arm’s-length principle can be permissible in certain circumstances. By Lena Angvik June 14 2018
