This content is from: Germany OECD agreement in Berlin marks beginning of the end for bank secrecy The OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes met in Berlin to form an agreement that marks the end for bank secrecy and shows that many jurisdictions referred to as tax havens a... By Sophie Ashley October 31 2014
This content is from: Transfer Pricing Israeli tech ruling brings preferred enterprise regime into the spotlight The Israeli Tax Authority (ITA) recently issued a pre-ruling which shows how tech companies can qualify for preferred enterprise tax breaks. The preferred enterprise regime is a step forward in the fight against base ... By Sophie Harding October 30 2014
This content is from: France France asserts PE in commissionaire structures again Eric Meier and Ariane Calloud, of Baker & McKenzie, analyse a recent case about potential permanent establishment of a French entity operating under a commissionaire arrangement with its Swiss principal. October 30 2014
This content is from: United States International Tax Review at 25: What has changed in a quarter of a century Tax has changed dramatically since the first issue of International Tax Review came out in November 1989. Using a selection of articles – one from each year – Ralph Cunningham and Matthew Gilleard assess how many of t... October 30 2014
This content is from: Bahrain Transfer pricing in the Gulf Cooperation Council In the past three years, the eyes of the global public have been drawn to the normally quiet world of international taxation by corporations structuring their businesses in a way that is perceived to be for no other p... October 30 2014
This content is from: Sponsored Canada: Recent treaty shopping developments In part, as a consequence of the OECD's work on BEPS and its specific efforts to address treaty shopping, the Canadian government has been considering a range of possible measures that might be adopted to counteract t... By ITR Correspondent October 30 2014
This content is from: Brazil Brazil makes changes to import and export pricing methods The Brazilian Federal Revenue Secretariat has issued Normative Instruction (NI) 1,498/2014, making changes to the list of commodities for the purpose of applying the PCI (price under quotation on importation) and PECE... By ITR Correspondent October 27 2014
This content is from: Australia Australia’s tax evasion drama: ATO rejects widespread non-compliance as it battles Chev... Industry and tax professionals have criticised the Tax Justice Network’s methodology in its report that alleges nearly one-third of the largest businesses in Australia are dodging taxes. By Meredith McBride in Hong Kong October 23 2014
This content is from: South Africa Lonmin accused of using profit shifting for wage evasion purposes The Alternative Information and Development Centre (AIDC) has released a report alleging that mining company Lonmin manipulated its transfer pricing for wage evasion purposes. By Sophie Harding October 22 2014
This content is from: United Kingdom Interest deductions: the new war on base erosion The G20 and OECD's Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for pro... By ITR Correspondent October 21 2014
This content is from: Luxembourg Luxembourg better defines TP rules amid EC investigations Luxembourg’s government has presented a draft budget to Parliament which includes changes to the transfer pricing rules. By Sophie Ashley October 21 2014
This content is from: Transfer Pricing IFA speakers address lack of progress in OECD’s intangibles work Defining intangibles is vital to the success of the OECD’s BEPS project because a clear definition is important for comparability and valuation. However, given the broad range of intangibles, deciding on one precise d... By Sophie Harding October 20 2014
This content is from: Australia Wood leads tax team to KPMG KPMG has hired three tax lawyers, partner Angela Wood and senior lawyers Ross Hocking and Angelina Lagana, from the severely depleted Maddocks tax controversy team. By Joe Stanley-Smith October 20 2014
This content is from: European Union Why taxpayers must resign themselves to increasing levels of public disclosure At the 68th IFA Congress in Mumbai panelists warned that taxpayers will need to prepare themselves for decreasing confidentiality levels in relation to company data. By Sophie Harding October 16 2014
This content is from: Ireland Double Irish is on borrowed time The Irish government announced in its 2015 Budget the abolition of the double-Irish structure and its intention to introduce an income-based system for the taxation of intellectual property, which it is calling a Know... By Ralph Cunningham October 16 2014
This content is from: India Bombay High Court rules in favour of Vodafone in TP share value controversy The Bombay High Court (HC) has ruled in favour of Vodafone India in relation to a transfer pricing dispute between the company and the tax authorities about whether the transfer of shares between the company and a sub... By Sophie Ashley October 12 2014
This content is from: India India: Transfer pricing aspects of restructuring Ever since the inception of the transfer pricing (TP) regulations in India, tax authorities have become increasingly vigilant when scrutinising the inter-company transactions and TP policies of multinationals (MNE), r... October 09 2014
This content is from: India Bombay High Court rules in favour of Vodafone on share issue In a decision that could give relief to more than 20 other pending cases, the Bombay High Court has ruled in favour of Vodafone that in the absence of income, a share issue transaction cannot be subjected to transfer ... By Matthew Gilleard October 09 2014
This content is from: India Industry calls for deferral of GAAR in India over fears country is not ready General anti-avoidance rules (GAAR) could come into effect from April 1 2015 but there is a chance the rules will once again be deferred as a result of opposition from the tax industry and corporates. By Sophie Harding October 08 2014
This content is from: European Union Local employment motivated Apple Ireland tax deal but it’s an isolated case The EC is investigating tax arrangements between Ireland and Apple because it thinks the tech company was given a financial advantage in exchange for creating jobs. By Sophie Harding October 06 2014
This content is from: Australia ATO TP staffing issue is being “overblown” Australian media has reported that the country’s tax office (ATO) is experiencing staffing issues in the transfer pricing department, which is impacting taxpayers, but advisers have said this is an overstatement. By Sophie Ashley October 06 2014
This content is from: European Union Ireland’s tax deals with Apple “constitute state aid”; Luxembourg’s Amazon arrangement ... Amazon has been drawn into a European Commission (EC) investigation into the tax regimes of three member states: Ireland, Luxembourg and the Netherlands. The EC has said its preliminary view on Ireland is that “the ta... By Matthew Gilleard October 05 2014
This content is from: China Alcatel-Lucent promotes Barsac to group head of transfer pricing October 05 2014
This content is from: Italy The Italian approach to intercompany loans The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. By ITR Correspondent October 05 2014
This content is from: Global OECD unveils plan for 2014/2015 BEPS work The OECD is getting straight back to work on base erosion and profit shifting (BEPS). By Ralph Cunningham October 01 2014
