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  • Berlin Conference
    ITR Global Transfer Pricing Forum – Berlin, June 29 & 30
    Almost a year after the final BEPS guidelines were released, some companies are still struggling to come to grips with the OECD’s recommendations.
    May 24 2016
  • Bald head eagle
    IRS targeting SMEs for transfer pricing audits
    The Internal Revenue Service has shifted its attention to transfer pricing audits of smaller US companies that it may have previously ignored, tax experts warn.
    Joelle Jefferis, May 24 2016
  • Kim Jacinto-Henares
    In focus: The Philippines grapples with transfer pricing
    TP Week embarks on a new series of features looking at up-and-coming jurisdictions for transfer pricing. This week, the Philippines is in the spotlight.
    Joelle Jefferis, May 22 2016
  • Apple state aid
    Ireland denies giving Apple sweetheart tax deal
    Has Ireland provided Apple with state aid or any other kind of special tax deal? Finance Minister Michael Noonan addressed parliament's questions.
    May 21 2016
  • Chevez Ruiz Zamarripa
    Private equity funds in Mexico: application of treaty benefits and concerns arising from BEPS Action 6
    Alfredo Sánchez Torrado and Eduardo García Ruiz examine the way in which investments are currently structured in Mexico via private equity funds, the application of treaty benefits by them, as well as how BEPS Action 6 may affect such application.
    May 20 2016
  • Hill
    IP migration strategies – pre-and post-BEPS
    BEPS aims to prevent aggressive profit-shifting strategies to better align transfer pricing outcomes with value creation. In this paper, Dale Hill, a partner at Gowling WLG, examines BEPS’s application to the transfer pricing aspects of intangibles and the impact on tax-motivated IP migration strategies.
    May 20 2016
  • BEPS: The endgame
    The boldest initiative in transfer pricing history entered the homestretch in October 2015 with the release of the OECD's final report on its base erosion and profit shifting (BEPS) project. The reverberations are being felt across North America, Europe, Asia and beyond.
    May 20 2016
  • Russo
    Intangibles in a post-BEPS world
    The framework for analysing intercompany transactions involving intangibles is examined by Hendrik Blankenstein and Caterina Colling Russo at Tax Partner AG – Taxand Switzerland. Does the new DEMPE analysis benefit MNEs and tax authorities or simply confuse matters, resulting in an increase of intangibles-related disputes?
    May 20 2016
  • forst
    Responding to the changes in the transfer pricing landscape
    The Internal Revenue Service appears to be strengthening its stand on aggregating transactions and applying economic substance rationales to override related-party contracts. David Forst and Larissa Neumann of Fenwick & West discuss US developments including the IRS and Treasury Department-issued 482 Temporary Regulations.
    May 20 2016
  • kim
    There is more to BEPS than meets the eye
    Much lies beneath the surface of BEPS. How will BEPS affect Korean multinationals and what do MNEs need to learn? Tae Hyung Kim, partner and senior transfer pricing economist at Deloitte Korea, explains exactly what multinationals must consider and what they should fear.
    May 20 2016
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