New French TP provisions call for tightening up of documentation but should lower audit... France recently enacted transfer pricing provisions detailing penalties taxpayers can incur for noncompliance regarding documentation requirements. A regularisation procedure has also been formally implemented which should reduce the cost of... By Sophie Harding February 02 2015
MAP and bilateral APA agreements with US signal breakthrough for India Mutual agreement procedures (MAPs) and advance pricing agreements (APA) between India and the US hint at closer ties between the two nations and reinforce India’s desire to be seen as... By Sophie Harding January 28 2015
Indian government decides not to appeal Bombay High Court ruling in Vodafone case The Indian government will not appeal the Bombay High Court (HC) ruling which concluded Vodafone was not accountable for a 3,200 crore ($525 million) tax demand. By Joseph Stanley-Smith & Sophie Harding January 28 2015
U-turn in CBSA’s stance on TP adjustments for customs purposes is welcome news for impo... The Canada Border Services Agency (CBSA) recently changed its policy on transfer pricing adjustments for customs purposes. The new policy allows eligible importers to seek refunds of custom duties where... By Sophie Harding January 27 2015
BEPS Action 10 feedback shows cost pool remains a contentious issue Public comments on BEPS Action 10 welcome the OECD’s simplified approach to dealing with low value-adding intra-group services and generally support the proposed profit mark-up range. By Sophie Harding January 26 2015
Mumbai ITAT sides with OECD on location savings in Watson Pharma case The Income-Tax Appellate Tribunal (ITAT) in Mumbai has ruled in favour of Watson Pharma Private, rejecting India’s views on location savings advantages in favour of the OECD perspective. By Sophie Harding January 22 2015
Action 7 feedback downplays OECD’s progress and hints at unravelling of universal approach Comments on Action 7 of the OECD’s base erosion and profit shifting (BEPS) project show the draft has done little to clarify permanent establishment (PE) issues with many countries considering... By Sophie Harding January 21 2015
Growing fear over wider implications of EC investigations after Amazon Luxembourg deal ... In a preliminary ruling, the European Commission (EC) has deemed tax deals between Luxembourg and Amazon as state aid. By Sophie Harding January 20 2015
Drastic changes to South African TP regime needed to align country with OECD BEPS work The Davis Tax Committee recently published recommendations for the OECD and the South African Revenue Service (SARS) regarding base erosion and profit shifting (BEPS). By Sophie Harding January 19 2015
UK takes profit shifting into its own hands with DPT proposal The UK government’s plans to introduce a Diverted Profits Tax (DPT), before the completion of the OECD’s work on base erosion and profit shifting (BEPS), could create uncertainty within the... By Sophie Harding January 14 2015
