Why Ireland’s tax system is viewed as a haven and not simply competitive Ireland’s tax system is frequently in the headlines, with numerous references made to its aggressive tax planning and active role as a tax haven. By Sophie Harding June 19 2014
AstraZeneca’s Ian Brimicombe addresses BEPS and US inversion transactions Ian Brimicombe, VP of corporate finance at AstraZeneca, discusses the struggle between regional and global compliance in an interview with TPWeek, and provides his views on topical transfer pricing issues. By Sophie Harding June 17 2014
Inspector-General’s review of the ATO uncovers inadequacies in TP planning and resources The Inspector-General of Taxation (IGT) has announced that his review of the Australian Taxation Office (ATO) uncovered “insufficient transfer pricing capability which was caused by inadequate succession planning and resource... By Sophie Harding June 09 2014
How to overcome inconsistency between REIT tax rules and TP rules in the US Real Estate Investment Trusts (REITs) in the US face difficulties when it comes to complying with both REIT tax rules and transfer pricing (TP) rules because the guidelines surrounding adjustments... By Sophie Harding June 08 2014
Switzerland and Singapore agree to exchange of tax information but mistrust ensues In May, both Switzerland and Singapore, often associated with banking secrecy, signed an OECD declaration agreeing to automatically exchange tax information. By Sophie Harding June 02 2014
How the sharing of taxpayer information can be commercially detrimental At the OECD Public Consultation on Transfer Pricing and Country-by-Country Reporting (CbCR) in May, taxpayers voiced their growing concerns about commercial sensitivity. By Sophie Harding May 27 2014
Changes to PE allocations in Japan may complicate foreign tax credit The Japanese Diet recently approved reforms to change the country’s general tax rules applicable to a foreign corporation (FC) with a permanent establishment (PE). By Sophie Harding May 26 2014
Taxpayers’ concern about commercial sensitivity discussed at OECD public consultation o... Commercial sensitivity has been the focus of the morning’s discussion at the OECD’s Public Consultation on Transfer Pricing Documentation and Country-by-Country Reporting (CbCR). By Sophie Harding May 18 2014
Country-by-country compliance burden could be relieved by cross-referencing says OECD p... The OECD’s public consultation on transfer pricing and country-by-country reporting (CbCR) today raised the possibility of cross-referencing in a company’s master file, to help ease the compliance burden for taxpayers... By Sophie Harding May 18 2014
US split over potential implications of BEPS The OECD BEPS project has created concern amongst some tax practitioners in the US, who argue it could increase cross-border disputes and reduce US tax revenue, putting the country’s tax... By Sophie Harding May 14 2014
