If your company’s board-level executives are not concerned about your transfer pricing operations your company could be at risk during audit. TPWeek speaks to in-house tax directors and their advisers to find out how transfer pricing became a board-level issue and what their companies are doing now.
Allegations that BHP Billiton and Rio Tinto shifted billions of dollars in iron ore profits through marketing hubs in Singapore has added fuel to the raging debate in Australia over tax avoidance involving multinationals.
Advance pricing agreements (APAs) statistics for 2014 in the US indicate the Internal Revenue Service’s (IRS) productivity has decreased by 30% from 2013.
The UN’s role in transfer pricing policy seems to have quietened since the release of its practical manual on transfer pricing for developing countries in 2013. Particularly now the OECD is dominating the headlines with its BEPS project.
India’s Income-Tax (I-T) Department announced the deadline for filing roll-back applications for transfer pricing agreements will be extended. This is welcome news for tax professionals who criticised the government’s aggressive timeline for advance pricing agreements (APAs).
China’s State Administration of Taxation (SAT) recently issued a notice regarding payments involving related offshore parties. China has openly declared its plans to crackdown on tax evasion, so the issuing of new regulations come as no surprise.
Rio Tinto’s “taxes paid” report for 2014 revealed the company paid $ 7.1 billion worth of taxes and royalties globally. The report also voiced Rio Tinto’s concerns over the OECD’s base erosion and profit shifting (BEPS) project and the potential for discrimination against multinationals.
Danish tax authority, SKAT, collected DKK 20 billion ($2.9 billion) in tax adjustments in 2014 by challenging 76 companies’ transfer pricing arrangements. The agency’s aggressive tax policy has been widely criticised by business with suggestions that government has an anti-business agenda.
India’s long-awaited advance pricing agreement (APA) roll-back provisions have been released. This will come as welcome news to taxpayers who criticised the government’s 2015 Budget for overlooking important transfer pricing issues.
The Income-Tax Department (I-T Department) has issued Cairn Energy (Cairn) with a Rs. 10,247 ($1.6 billion) tax demand over its transfer of assets to Cairn India. The tax demand draws similarities with Vodafone and suggests India still has work to do in proving itself as an investor-friendly nation.
Italy has introduced a patent box regime based on the OECD’s nexus approach, which will grant exemptions for profits derived from certain intangible assets for corporate and regional tax purposes. Italy’s alignment with the OECD should keep the usual patent box-related criticism at bay.
HM Revenue & Customs (HMRC) recently released its transfer pricing statistics for 2013-14. While HMRC collected almost twice as much in additional taxes compared with 2012-13, the time taken to resolve advance pricing agreements (APAs) and mutual agreement procedures (MAPs) has increased.