This content is from: France Nicolas Colin discusses French report on digital economy taxation Earlier this year Pierre Collin and Nicolas Colin authored a report, commissioned by the French government, focusing on the taxation of the digital economy. The report focuses on how to measure the taxable profits by ... By Sophie Ashley November 27 2013
This content is from: Transfer Pricing Armando Lara Yaffar discusses the development of the UN TP manual Armando Lara Yaffar, chairman of the UN tax committee and the deputy director general for international treaties within the department of revenue and public credit at the Ministry of Finance in Mexico, discusses the d... By Sophie Ashley November 26 2013
This content is from: Germany The two-step approach to permanent establishment profit attribution in Germany Xaver Ditz and Carsten Quilitzsch, of Flick Gocke Schaumburg, explain the two-step approach to PE profit attribution in Germany November 20 2013
This content is from: Australia New Zealand’s Inland Revenue compliance requirements impact transfer pricing Taxpayers in New Zealand have been told exactly what is expected of them in a new document outlining compliance requirements and the approach the Inland Revenue will take towards cross-border financing, controlled for... By Sophie Ashley November 19 2013
This content is from: United States An update on Eaton Corporation, Amazon and Altera US transfer pricing trials Next year should see three big transfer pricing litigation cases come to trial in the US: Eaton Corporation, Amazon and Altera. All cases will have a significant impact on taxpayers with possible repercussions on an i... By Sophie Ashley November 19 2013
This content is from: China China introduces mutual agreement process China’s State Administration of Taxation (SAT) implemented a measure for taxpayers to take advantage of mutual agreement procedures (MAP) for the resolution of cross-border tax disputes this month. By Joe Dalton November 18 2013
This content is from: Transfer Pricing BIAC addresses OECD with closing remarks on transfer pricing consultation Will Morris, chairman of BIAC’s (business advisory arm to the OECD) tax and fiscal policy committee, closed the OECD’s public transfer pricing consultation in Paris yesterday by praising the organisation’s inclusion o... November 14 2013
This content is from: France Arm’s-length principle is still being called into question At the OECD’s public consultation in Paris this week, the arm’s-length principle was called into question a number of times by speakers. By Sophie Ashley November 14 2013
This content is from: United Kingdom Astra Zeneca provides a critique of the global master file for transfer pricing documen... Many multinational companies choose to adopt a global master file system when complying with national transfer pricing documentation requirements. Astra Zeneca provided a critique of the concept as part of the discuss... November 14 2013
This content is from: France OECD questions the reality of implementing country-by-country reporting In a public consultation on transfer pricing matters in Paris today, the OECD questioned the realities of implementing country-by-country (CBC) reporting, with business’s main concern centring on confidentiality. By Sophie Ashley November 12 2013
This content is from: France The future of marketing intangibles in OECD guidance Delegates attending the OECD’s public consultation on transfer pricing matters in Paris today discussed whether marketing intangibles should be included in new guidance or not. By Sophie Ashley November 12 2013
This content is from: United States OECD questions country-by-country reporting implementation after confidentiality concerns In a public consultation on transfer pricing matters in Paris today, the OECD questioned the realities of implementing country-by-country (CBC) reporting, with business harbouring concerns over the confidentiality of ... By Sophie Ashley November 12 2013
This content is from: France Objection to tweeting in OECD public consultation on transfer pricing matters A delegate to the OECD public consultation on transfer pricing has objected to live tweeting during the event By Sophie Ashley November 12 2013
This content is from: United States Why US Tax Court refused to grant Medtronic's protective order Medical technology multinational, Medtronic, could suffer after the US Tax Court denied the company's request for a protective order in its transfer pricing case. By Joe Dalton November 07 2013
This content is from: Brazil Why South Africa is holding back on transfer pricing guidance South African taxpayers are still waiting for the revenue authority to publish guidelines on the transfer pricing rules that were implemented in April 2012, despite the authorities stating that the old rules and guida... By Sophie Ashley November 06 2013
This content is from: Germany Germany’s new rules on profit allocation to insurance PEs Ulf Andresen and Jobst Wilmanns of PwC in Frankfurt, explain how Germany’s new profit allocation rules for insurance permanent establishments (PE) potentially discriminate against foreign insurers. November 01 2013
