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 exclusive interview.
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 of the rules.
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 tax litigation team.
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.
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 Week.
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 the EU.
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 decision that could trigger double taxation under India’s equalisation levy.
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 Business, tells TP Week why the EU’s focus on profit split concerns him and what it could mean for impacted businesses.
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. The ruling is expected to have a significant impact on cross-border transfer pricing adjustments.
An OECD discussion draft on intra-group financial transactions is slated for release in July. Stakeholders hope the OECD can provide some much-needed principles on financial transactions such as intra-group guarantees to avoid differences between countries that lead to transfer pricing controversy.