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Transfer Pricing

An intense period of lobbying and persuasion is under way as the UN secretary-general’s report on the future of international tax cooperation begins to take shape. Ralph Cunningham reports.
The OECD’s rules may be impossible for businesses to manage, according to tax experts from companies including Shell.
EY is still negotiating the terms of the plan to split its audit and consulting functions, but the future of tax services is reportedly a sticking point.
Country-by-country reporting is the best option for safe harbour provisions under the global anti-base erosion rules, according to tax directors at companies including Standard Chartered Bank and Pernod Ricard.


The Supreme Court of Canada will decide a crucial issue of jurisdiction for taxpayers in a transfer pricing dispute between Dow Chemical and the Canada Revenue Agency.
Dow Chemical Canada is taking a transfer pricing dispute to the highest court, while China is reportedly marginalising the ‘big four’ auditors.
The EU may have to take the lead on international taxing rights if the OECD’s pillar one falls short this year, but global divisions persist.
Hong Kong SAR’s 2023-24 budget sets out tax changes such as a patent box and one-off cuts to support the COVID-19 economic recovery.
The EU should not rule out implementing pillar one on its own if global talks fail, according to French Finance Minister Bruno Le Maire.
A two-day OECD conference acknowledged that the international agreement on pillar one is moving forward, but there is still plenty of TP work to do.
The Tax Cuts and Jobs Act helped lay the basis for the OECD’s two-pillar solution, and its global significance for TP is even more clear in 2023.
The EU and OECD may be breaking with the arm’s-length principle in favour of limited formulary apportionment, but businesses will still be able to achieve tax efficiency.
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2023 ITR Tax Awards in Asia-Pacific, Europe Middle East & Africa, and the Americas.
The winners of the ITR Americas Tax Awards have been announced for 2022!
The winners of the ITR EMEA Tax Awards have been announced for 2022!
12th annual awards announce winners