This content is from: United States Why do publicly-traded companies like Ireland? Publicly-traded companies seemingly have an affinity towards Ireland. Is it purely a pursuit of the Emerald Isle’s temperate climate that attracts them? Conor Hurley and Ailish Finnerty of Arthur Cox analyse the facto... May 31 2014
This content is from: United States Transfer pricing: Still problematic for global corporations The growing complexity of worldwide transfer pricing rules continues to expand documentation requirements, transparency initiatives and audits, all of which create challenges for multinational companies, believe Nancy... May 31 2014
This content is from: Canada Canada intangibles guide By Brad Rolph, Glen Haslhofer and Peter Kurjanowicz of Grant Thornton Canada May 28 2014
This content is from: Transfer Pricing How the sharing of taxpayer information can be commercially detrimental At the OECD Public Consultation on Transfer Pricing and Country-by-Country Reporting (CbCR) in May, taxpayers voiced their growing concerns about commercial sensitivity. Many taxpayers worry that information could be ... By Sophie Harding May 27 2014
This content is from: Russia Russian de-offshoring may affect international businesses Taxation of cross-border structures and new exchange of information measures are two reasons why Russia’s new de-offshoring policy will have an impact on foreign as well as domestic groups, explain Estella Dzhantukhan... May 26 2014
This content is from: Global Avoiding the snares of international tax structures International business expansions can substantially increase the bottom line, but this outcome is largely dependent on establishing an efficient structure that helps to ensure financial success. Lee Sheehan, head of t... May 26 2014
This content is from: India Indian ruling shows price quotations can be used as a CUP but danger lurks The High Court of Gujarat in India, has upheld the use of price quotations as comparable uncontrolled prices (CUP) if the quotations are “reliable and authentic” in the case of Adani Wilmer, an edible oil producer. By Sophie Ashley May 26 2014
This content is from: United States Transfer pricing: Still problematic for global corporations The growing complexity of worldwide transfer pricing rules continues to expand documentation requirements, transparency initiatives and audits, all of which create challenges for multinational companies, believe Nancy... May 26 2014
This content is from: Sponsored Asia tax directors do battle with lengthy in-tray The two-day Asia Tax Forum covered a range of issues and countries, not just BEPS, including dispute resolution and anti-avoidance, transfer pricing and China’s VAT reforms, reports Ralph Cunningham. May 26 2014
This content is from: United States Why do publicly-traded companies like Ireland? Publicly-traded companies seemingly have an affinity towards Ireland. Is it purely a pursuit of the Emerald Isle’s temperate climate that attracts them? Conor Hurley and Ailish Finnerty of Arthur Cox analyse the facto... May 26 2014
This content is from: Sponsored Australia: Draft guidance on new Australian transfer pricing rules May 26 2014
This content is from: United States Inversions: The trend turning transactional tax planning upside down Mention the word ‘inversion’ or ‘inverted’ and the first things likely to come to mind for most people are inverted commas – the most supercilious of the English language’s punctuation marks, looking down on regular c... By Matthew Gilleard May 26 2014
This content is from: Japan Changes to PE allocations in Japan may complicate foreign tax credit The Japanese Diet recently approved reforms to change the country’s general tax rules applicable to a foreign corporation (FC) with a permanent establishment (PE). The reforms, which highlight the OECD’s growing influ... By Sophie Harding May 26 2014
This content is from: Transfer Pricing Ugandan trade mis-invoicing showcases chronic development hurdle A new survey has highlighted that Uganda lost approximately $884 million in 2002 to 2011 through transfer mis-invoicing. Reasons cited for constant increases in tax revenue losses include a mix of bribery, lack of gov... By Jon Montgomery May 22 2014
This content is from: Austria European Tax Awards' winners unveiled The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21. By ITR Correspondent May 21 2014
This content is from: Transfer Pricing BEPS: Why banks cannot afford to ignore the developments Banks may be relieved that in recent months the media focus on tax affairs has turned to the digital economy. But the OECD response via the base erosion and profit shifting (BEPS) action plan has momentum and could f... By ITR Correspondent May 21 2014
This content is from: Global World Tax 2016 and World Transfer Pricing 2016: Research opens in May 2015 The research will start for the 2016 editions of World Tax and World Transfer Pricing in May 2015. Please watch this website closely for further information. By Salman Shaheen May 20 2014
This content is from: Transfer Pricing Country-by-country compliance burden could be relieved by cross-referencing says OECD p... The OECD’s public consultation on transfer pricing and country-by-country reporting (CbCR) today raised the possibility of cross-referencing in a company’s master file, to help ease the compliance burden for taxpayers... By Sophie Harding May 18 2014
This content is from: Transfer Pricing Taxpayers’ concern about commercial sensitivity discussed at OECD public consultation o... Commercial sensitivity has been the focus of the morning’s discussion at the OECD’s Public Consultation on Transfer Pricing Documentation and Country-by-Country Reporting (CbCR). By Sophie Harding May 18 2014
This content is from: India Delhi tribunal overrules TPO to set profit split precedent An Indian member of the EQUANT group (formerly Global One India) recently defended its application of the profit split method (PSM) against the transfer pricing officer (TPO). The ruling has provided guidance on the p... By Jon Montgomery May 18 2014
This content is from: Germany Germany intangibles guide By Alexander Voegele and Jean-Benoit Voegele of NERA Economic Consulting May 16 2014
This content is from: United States US split over potential implications of BEPS The OECD BEPS project has created concern amongst some tax practitioners in the US, who argue it could increase cross-border disputes and reduce US tax revenue, putting the country’s tax base at risk. Others feel t... By Sophie Harding May 14 2014
This content is from: Australia Australian thin cap reforms likely to have detrimental impact on highly leveraged multi... The Australian exposure draft legislation, released on May 8 2014, aims to target base erosion and profit shifting and limit multinationals’ ability to pay deductible returns to shareholders. The reforms have generate... By Sophie Harding May 14 2014
This content is from: Direct Tax IRS, World Bank and top corporate taxpayers to discuss BEPS at global transfer pricing ... International Tax Review and TPWeek’s 14th Global Transfer Pricing Forum will be held on September 22 and 23 at the Park Hyatt hotel in Washington, DC. May 13 2014
This content is from: Italy Negotiating Italy’s Arbitration Convention Arbitration Convention No. EEC/90/436, approved on July 23 1990, sets forth an arbitration procedure for the settlement of double taxation issues deriving from diverging transfer pricing adjustments applied by associa... By ITR Correspondent May 12 2014
This content is from: Transfer Pricing IRS, World Bank and top multinational taxpayers to discuss BEPS and related issues in g... TPWeek and International Tax Review’s 14th Global Transfer Pricing Forum will be held on September 22 and 23 at the Park Hyatt hotel in Washington, DC. May 12 2014
This content is from: Transfer Pricing Dominican Republic documentation guide By Fabián Alfonso, partner, and Ivo Santamaria, senior manager, lead BaseFirma’s Miami, US practice and Juan Sebastián Triana is an associate with BaseFirma in Bogotá, Colombia. May 12 2014
This content is from: Belgium EU JTPF’s updates signal increase in transparency but double taxation challenges remain The EU’s Joint Transfer Pricing Forum (JTPF) published transfer pricing (TP) profiles of the EU Member States last month, promoting transparency. However, concern remains over how the Arbitration Convention (AC) will ... By Sophie Harding May 11 2014
This content is from: India Why using a hotel for business purposes could result in PE classification In a recent ruling, the Mumbai Income Tax Appellate Tribunal (ITAT) concluded that the hotel rooms used by Renoir Consulting for its staff in India constituted a permanent establishment (PE), despite the fact manageme... By Sophie Harding May 08 2014
This content is from: Italy Italian 2014 stability law: Amendments to international tax ruling provisions The Italian stability law has been amended in relation to international tax ruling provisions. By ITR Correspondent May 06 2014
This content is from: Transfer Pricing Mining companies accused of transfer mispricing in Ghana New allegations have emerged from non-government agencies (NGO) such as Tax Justice Network Africa and Christian Aid that mining companies are hiding behind transfer pricing (TP) to dodge taxes in Ghana. By Sophie Harding May 06 2014
