Acting ahead of final OECD recommendations could put BEPS project in jeopardy With the deadline for the base erosion and profit shifting (BEPS) project still some time away, governments are deliberating whether to take the issue into their own hands and act... By Sophie Harding February 24 2015
IRS threatens to penalise Caterpillar over profits earned from Swiss subsidiary After investigating Caterpillar’s US tax returns, the Internal Revenue Service (IRS) is threatening to tax profits the company earned from its Swiss based subsidiary (Caterpillar SARL). By Sophie Harding February 24 2015
Level of confidentiality in CbCR continues to be Achilles' heel of the OECD’s BEPS project The OECD’s implementation guidance on country-by-country reporting (CbCR) has done little to placate the debate between multinationals and non-government organisations (NGOs) over the degree of confidentiality required in documentation. By Sophie Harding February 18 2015
ATO says ECAP programme is only in pilot stages and dismisses claims it would aid tax c... The Australian Taxation Office (ATO) has been accused of pushing for big corporations to conduct their own tax audits. Negative comments in the media and statements from alleged employees claim... By Sophie Harding February 13 2015
Hasbro agrees to pay Mexican SAT $4.38 million over tax avoidance claims A spokesperson for US toy company Hasbro announced the company had agreed to pay the Mexican tax authorities (SAT) $65 million ($US 4.38 million) to settle tax avoidance claims. By Sophie Harding February 11 2015
Hong Kong shows eagerness to provide tax certainty with conclusion of first bilateral A... Hong Kong’s Inland Revenue Department (IRD) has concluded its first bilateral advance pricing agreement (APA) with the Japanese tax authorities. The APA highlights the IRD’s willingness to cooperate with other... By Sophie Harding February 10 2015
PAC report makes an example of PwC and urges HMRC to take a more active role in challen... The Public Accounts Committee (PAC) released a report on tax avoidance, focusing primarily on tax arrangements between pharmaceutical company Shire and PwC. By Sophie Harding February 06 2015
French oil company Total to close all tax haven subsidiaries in bid to promote transpar... French oil company Total has announced plans to close subsidiaries in tax havens in a bid to prove it is making conscious efforts to clean up its tax policy. By Sophie Harding February 06 2015
Amendments to TP rules and the proposed introduction of CbCR suggest greater alliance b... The Spanish government recently changed its transfer pricing rules regarding documentation requirements and penalties. These amendments show Spain is aligning itself more closely to OECD guidelines. By Sophie Harding February 04 2015
India’s CBDT asks ITAT and DRP to apply Vodafone ruling to similar transfer pricing cases The Central Board of Direct Taxes (CBDT) has requested that Income Tax Appellate Tribunals (ITAT) and dispute resolution panels (DRP) apply the principle behind the Bombay High Court’s Vodafone ruling... By Sophie Harding February 02 2015
