ITR Search | International Tax Review

EMEIA: Base erosion, profit shifting and the effects on transfer pricing

Base erosion and profit shifting (BEPS) is intended to describe the phenomenon that governments lose substantial corporate tax revenue because of planning aimed at eroding the taxable base and/or shifting profits to locations where they are subject to more favourable tax treatment. Oliver Wehnert, Ernst & Young’s EMEIA transfer pricing leader, explains the impact the project may have on transfer pricing.

June 11 2013

UN China chapter: Issues raised on contract R&D

The inclusion of the China country practices chapter, as part of the UN Practical Manual on Transfer Pricing for Developing Countries (draft version) indicates a great leap in the transfer pricing (TP) administration of the State Administration of Taxation (SAT). Han Jin Ping, tax manager at Siemens, China, discusses the importance of the chapter and the international message it conveys on contract R&D.

June 11 2013

The game changer

This year has been a game changer for global transfer pricing. With the final release of the UN Practical Transfer Pricing Manual for Developing Countries in May and with consistent developments in the OECD's transfer pricing aspects of intangibles project – not to mention its new Base Erosion and Profit Shifting (BEPS) project – the goalposts for companies' transfer pricing compliance requirements are changing.

June 11 2013

US transfer pricing developments

There have been a number of important US developments in transfer pricing in the past 12 months. Kenneth Clark, Ronald Schrotenboer and David Forst of Fenwick & West provide a brief review and highlight a number of these developments.

June 11 2013

Ways & Means chairman Dave Camp to examine US BEPS issues

United States House Ways & Means Committee chairman Dave Camp will hold a hearing on Thursday to examine US and foreign multinationals’ use of tax havens to avoid tax and shift profits outside of the US.

Matthew Gilleard, June 10 2013

How French taxpayers should prepare for a tougher TP regime

The French Ministry of Finance has proposed tightening the country’s transfer pricing regulation and setting tougher penalties for taxpayers who fail to comply. Advisers say the recommendations are likely to be included in a draft finance bill later this year.

Emma Powell, June 10 2013

UK debt-for-equity swaps to become taxable under HMRC proposal

The UK tax authority has published a consultation paper to seek stakeholder feedback on its proposals to modernise the taxation of corporate debt and derivative contracts. But the paper also features a proposal that could end companies’ ability to perform tax-free debt-for-equity swaps.

Matthew Gilleard, June 10 2013

Commission denies FTT rumours

The European Commission has denied the financial transaction tax (FTT) is set to be watered down.

Salman Shaheen, June 10 2013

What you have missed on ITR Premium

China – Netherlands tax treaty; German patent box; Vijai Electricals judgement; Vodafone conciliation; China VAT pilot; Luxembourg accounting systems; Authorised tax collection in China; OECD mutual administrative assistance in tax matters.

June 09 2013

Treaties of the week - June 10 2013

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement China Netherlands May 31 2013 Tax Information Exchange Agreement Bahrain Canada June 4 2013 Tax Information Exchange Agreement Japan Samoa June 4 2013 Tax Information Exchange Agreement Antigua and Barbuda Belgium June 5 2013

June 09 2013

Search results for