This content is from: Austria European Tax Awards 2014 The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21. By default\Anonymous June 30 2014
This content is from: Sponsored Germany: Global-China cash pooling and transfer pricing implications June 30 2014
This content is from: United States Transfer pricing risk management: A case for APAs Victor Adegite of KPMG Nigeria looks at the advance pricing agreement (APA) option as a tool taxpayers can use as part of their transfer pricing risk management, highlighting the benefits of different types of APA and... June 30 2014
This content is from: United States BEPS scepticism still rife despite OECD’s attempts at reassurance The OECD’s base erosion and profit shifting (BEPS) project has been a bone of contention in the transfer pricing arena ever since its inception, with concerns from taxpayers piling up despite constant efforts at reass... June 30 2014
This content is from: Global In search of harmony: Finding a consensus on hybrid mismatches Mismatches create opportunities. This is true in any scenario, whether it is the opportunity for a fleet-footed and nimble winger to gain an advantage by exposing the bulky, flat-footed front-row rugby forward who has... June 30 2014
This content is from: Canada Marzen Aluminum ruling based on structuring rather than pricing In the first decision of its kind, the Tax Court of Canada ruled that while Marzen Artistic Aluminum provided sales and marketing staff to Starline International at arm's-length, the documentation provided was insuffi... By Sophie Harding - ITR June 30 2014
This content is from: Global BEPS and the digital economy: Why is it so taxing to tax? Devising appropriate rules for the taxation of the digital economy is one of the most awkward challenges governments have set for themselves in the BEPS project, especially when defining the digital economy is an issu... June 30 2014
This content is from: France What chief financial officers need from their tax directors Jean-Louis Huchant, a former chief financial officer in France, explains what information and support a CFO requires from a tax director to ensure that tax considerations are taken into account, though do not dominate... June 30 2014
This content is from: United States BEPS and CbCR: A retrapolation five years on One of the most contentious issues being considered as part of the OECD’s base erosion and profit shifting (BEPS) project is the notion of country-by-country reporting (CbCR) of multinational companies' tax informatio... June 30 2014
This content is from: Transfer Pricing Fiat’s Andrea Bonzano talks BEPS, formulary apportionment and the profit split method Andrea Bonzano, head of tax at Fiat, discusses the pros and cons of different transfer pricing methods in an interview with TPWeek, and provides his views on BEPS and US inversions. By Sophie Harding June 29 2014
This content is from: Transfer Pricing Fiat’s Andrea Bonzano discusses its global transfer pricing strategy and preferred meth... Andrea Bonzano, head of tax at Fiat, discusses his company’s global transfer pricing strategy, including its preferred methodologies and how it is responding to BEPS discussions. June 29 2014
This content is from: Canada Canada: Transfer pricing aspects of restructuring By Jamal Hejazi, chief economist, Dale Hill, partner and Mark Kirkey, partner, of Gowling Lafleur Henderson – Taxand. June 26 2014
This content is from: Brazil New Baker & McKenzie partners announced By ITR Correspondent June 25 2014
This content is from: Canada Marzen Aluminum ruling based on structuring rather than pricing The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The rul... By Sophie Harding June 25 2014
This content is from: United States Michael Danilack resigns Michael Danilack, US Competent Authority, has confirmed with TPWeek that he has resigned from his post. June 24 2014
This content is from: United Kingdom UK: Transfer pricing aspects of restructuring By Wendy Nicholls, Sarah Morrissy and Jat Sandhu, Grant Thornton UK LLP By ITR Correspondent June 22 2014
This content is from: United States Transfer Pricing Focus 2014 now available BEPS has taken centre stage in global transfer pricing over the past year and recent debates have focused on country-by-country reporting, among other things. The issue of profit shifting has consequently been a stron... June 22 2014
This content is from: India ITAT overrules TPO’s adjustment concluding taxpayer was simply a mediator for parent co... The Income-Tax Appellate Tribunal (ITAT) in Delhi has overruled a transfer pricing adjustment, finding the taxpayer’s activity was low risk and consisted primarily of agency services. The ITAT ruled against the tran... By Sophie Harding June 22 2014
This content is from: India Indian High Court rules on payments for intra-group services The Delhi High Court has ruled on some of the crucial aspects that determine the tax deductibility of payments towards intra-group services in the case of Cushman and Wakefield (India). June 19 2014
This content is from: United States Americas Tax Awards 2014 - Make sure your company or firm is in the running The research process for International Tax Review’s Americas Tax Awards 2014 has begun. This is your chance to participate. By Ralph Cunningham June 19 2014
This content is from: Ireland Why Ireland’s tax system is viewed as a haven and not simply competitive Ireland’s tax system is frequently in the headlines, with numerous references made to its aggressive tax planning and active role as a tax haven. The UK, on the other hand, is being applauded for its competitive struc... By Sophie Harding June 19 2014
This content is from: Singapore Singapore intangibles guide By Nicole Fung and Michael Nixon, PwC Singapore June 19 2014
This content is from: Transfer Pricing AstraZeneca’s Ian Brimicombe discusses its global transfer pricing strategy Ian Brimicombe, VP of corporate finance for multinational pharmaceutical company AstraZeneca, discusses his company’s global transfer pricing strategy, including how it is focusing on the BEPS debate and the tax motiv... June 17 2014
This content is from: Transfer Pricing AstraZeneca’s Ian Brimicombe addresses BEPS and US inversion transactions Ian Brimicombe, VP of corporate finance at AstraZeneca, discusses the struggle between regional and global compliance in an interview with TPWeek, and provides his views on topical transfer pricing issues. By Sophie Harding June 17 2014
This content is from: United States Financial Services Focus 2014 now available Ahead of the launch of International Tax Review's Financial Services Tax website, the annual publication on Capital Markets tax developments has been repositioned to offer a greater breadth of topical coverage for fin... June 16 2014
This content is from: United States Base Firma and Quantera Global form strategic alliance By ITR Correspondent June 15 2014
This content is from: European Union Apple, Fiat and Starbucks rulings attract state aid investigations The European Commission has opened formal state aid investigations into three tax rulings agreed between Apple, Fiat and Starbucks with the Irish, Luxembourg and Netherlands tax authorities, respectively. By Matthew Gilleard June 12 2014
This content is from: Australia Inspector-General’s review of the ATO uncovers inadequacies in TP planning and resources The Inspector-General of Taxation (IGT) has announced that his review of the Australian Taxation Office (ATO) uncovered “insufficient transfer pricing capability which was caused by inadequate succession planning and ... By Sophie Harding June 09 2014
This content is from: Hong Kong SAR Hong Kong-Switzerland double tax treaty Since Hong Kong amended its tax law in 2010 to enable the adoption of the latest OECD information exchange standards in its tax treaties, it has made several moves to negotiate new treaties, and a double tax treaty wi... June 08 2014
This content is from: Russia Russia-Switzerland double tax treaty The protocol of amendment to the Russia-Switzerland double tax treaty (DTT), signed on September 24 2011, entered into force last month on November 9. The revised treaty, which contains updated information exchange pr... June 08 2014
This content is from: India India-UK double tax treaty India and the UK have signed a protocol to update the 1993 tax treaty between the two countries, introducing new measures including changes to partnership taxation, an article on assistance in the collection of taxes ... June 08 2014
This content is from: India India-Singapore double tax treaty The limitation-of-benefit clause in the India-Singapore treaty, offers greater clarity and comfort for investors residing in the country, helping to make Singapore India’s top source of foreign direct investment. June 08 2014
This content is from: Argentina Argentina-Spain double tax treaty Argentina and Spain signed a new double taxation treaty (DTT) on March 11 2013, replacing the version that was terminated in June 2012. Guillermo Teijeiro, founding partner of Teijeiro & Ballone Abogados, analyses the... June 08 2014
This content is from: Argentina Argentina-Switzerland double tax treaty Argentina has signed a new double tax treaty with Switzerland. The original accord was terminated in 2012, when Argentina also unilaterally terminated its treaties with Chile and Spain. June 08 2014
This content is from: Canada Hong Kong-Canada double tax treaty The long-awaited and much-lobbied-for tax treaty between Canada and Hong Kong was signed on November 11 and should facilitate investment between the two countries. June 08 2014
This content is from: Hong Kong SAR Hong Kong-Mexico double tax treaty Mexico has become the first North American country to sign a tax treaty with Hong Kong. The new treaty will make it easier for Mexican outbound investment to Asia. June 08 2014
This content is from: Albania UK-Albania double tax treaty The representatives of the two governments signed a treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital. June 08 2014
This content is from: United States How to overcome inconsistency between REIT tax rules and TP rules in the US Real Estate Investment Trusts (REITs) in the US face difficulties when it comes to complying with both REIT tax rules and transfer pricing (TP) rules because the guidelines surrounding adjustments are contradictory. By Sophie Harding June 08 2014
This content is from: China China-Netherlands double tax treaty On May 31 2013, China and the Netherlands signed a new double taxation avoidance treaty which will come into effect in 2014. June 08 2014
This content is from: Transfer Pricing OECD CbCR consultation coverage special focus Last month's public consultation at the OECD in Paris focused on country-by-country reporting (CBCR) in relation to multinationals’ transfer pricing documentation. TPWeek attended the consultation and provided live co... June 04 2014
This content is from: India India intangibles guide By Karishma Phatarphekar, partner, global transfer pricing services, KPMG India June 03 2014
This content is from: Italy Italian Supreme Court ruling maintains arm’s-length principle must apply to related com... The Italian Supreme Court ruled, on April 16, that all transactions carried out between companies belonging to the same group, and all of which have offices in Italy, are subject to the arm’s length principle. By ITR Correspondent June 03 2014
This content is from: United States Ryan adds transfer pricing with purchase of Altus International By ITR Correspondent June 03 2014
This content is from: Singapore Switzerland and Singapore agree to exchange of tax information but mistrust ensues In May, both Switzerland and Singapore, often associated with banking secrecy, signed an OECD declaration agreeing to automatically exchange tax information. The countries’ willingness to sign the document has been se... By Sophie Harding June 02 2014
This content is from: Russia Russia intangibles guide By Henrik Hansen, Evgenia Veter and Alexey Sobchuk of Ernst & Young, Russia June 02 2014
This content is from: European Union EC digital economy taxation report calls for adaptation of rules The EC has released a report on the taxation of the digital economy which states that some rules may need to be adapted in member states but a special tax regime is not necessary. By Joseph Stanley-Smith June 02 2014
This content is from: Kenya Why companies should readdress their tax structures in Africa As more companies invest in sub-Saharan Africa they encounter the uncertainties connected to the tax and legal regulations when extracting profits to be repatriated. But, with Africa fast becoming the alternative to I... June 02 2014
This content is from: Canada Canada adopts similar position to US and omits references to OECD in TP request Canada has followed suit with the US and has omitted references to the OECD’s three-tier documentation in favour of its own country specific transfer pricing (TP) documentation. June 01 2014
