Transfer Pricing

Archive: Transfer Pricing

This content is from: Canada

Canada Revenue Agency ignores the OECD’s simplified proposals for intra-group services ...

The Canada Revenue Agency (CRA) has released transfer pricing memorandum TPM-15 on intra-group services which overlooks the OECD’s proposals for a more simplified approach.
By Sophie Harding
February 26 2015
This content is from: South Africa

Transfer pricing steals the show in South African finance minister’s 2015-2016 budget s...

South African finance minister, Nhlanhla Nene, has stressed the importance of regulating transfer pricing to tackle profit shifting in the country in his 2015/2016 budget speech.
By Sophie Harding
February 26 2015
This content is from: South Africa

Michael Honiball joins Werksmans Attorneys

On February 1 2015, Michael Honiball joined Werksmans Attorneys in Johannesburg as a director.
February 26 2015
This content is from: United States

US Multistate Tax Commission proposes TP regime to tackle interstate income shifting

The US Multistate Tax Commission’s (MTC) Arm’s Length Adjustment Services (ALAS) programme is a response to interstate income shifting. The MTC hopes to provide state governments with a comprehensive programme to incr...
By Sophie Harding
February 25 2015
This content is from: Hong Kong SAR

Pieter de Ridder joins Mayer Brown JSM in Singapore
By Meredith McBride in Hong Kong
February 25 2015
This content is from: United States

IRS threatens to penalise Caterpillar over profits earned from Swiss subsidiary

After investigating Caterpillar’s US tax returns, the Internal Revenue Service (IRS) is threatening to tax profits the company earned from its Swiss based subsidiary (Caterpillar SARL). Caterpillar claims nothing unto...
By Sophie Harding
February 24 2015
This content is from: European Union

Keeping track of a shifting transfer pricing landscape

Maik Thomas Heggmair of WTS discusses recent transfer pricing changes in Germany, including the adoption of the authorised OECD approach (AOA) into German legislation and incoming reporting changes and provides practi...
February 24 2015
This content is from: United States

Areas of TP scrutiny in a pre- and post-BEPS world

Larissa Neumann, partner at Fenwick & West, assesses the transfer pricing landscape in the US, looking at authority attitudes and areas of focus based on recent dispute cases, and points to the need for consensus on t...
February 24 2015
This content is from: Transfer Pricing

Acting ahead of final OECD recommendations could put BEPS project in jeopardy

With the deadline for the base erosion and profit shifting (BEPS) project still some time away, governments are deliberating whether to take the issue into their own hands and act ahead of final OECD recommendations i...
By Sophie Harding
February 24 2015
This content is from: Global

The Brockman brief: Interest: Double taxation equality is fading

In the first of his regular monthly updates, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, looks at why countries are enacting unilateral legislatio...
February 24 2015
This content is from: European Union

Looking to the future: Life after the ‘Double Irish’

Competitive tax regimes and tax-planning strategies have been increasingly in the spotlight over the past 18 months or so, and the international tax landscape is changing. Louise Kelly, tax partner at Deloitte, looks ...
February 24 2015
This content is from: United States

TRIBUTE – the permanent tax treaty arbitration tribunal

International Tax Review’s Joe Stanley-Smith speaks exclusively to Hans Mooij, the architect of TRIBUTE – an organisation looking to shake up the world of tax arbitration.
By Joe Stanley-Smith
February 20 2015
This content is from: Transfer Pricing

ICC attempts to close gap between TP and customs

The International Chamber of Commerce (ICC) has released a statement on the challenges of harmonising indirect tax and transfer pricing.
By Sophie Ashley
February 19 2015
This content is from: India

Budget preview: Siemens on how tax may hold the key to 'Make in India'

With the Indian Budget fast-approaching, Subhankar Sinha, senior vice president, head of tax for the South Asia region at Siemens, looks at the tax measures that could be used to incentivise the government's 'Make in ...
February 18 2015
This content is from: Transfer Pricing

Level of confidentiality in CbCR continues to be Achilles' heel of the OECD’s BEPS project

The OECD’s implementation guidance on country-by-country reporting (CbCR) has done little to placate the debate between multinationals and non-government organisations (NGOs) over the degree of confidentiality require...
By Sophie Harding
February 18 2015
This content is from: India

Indian budget 2015: What taxpayers want to hear on indirect share transfers

Taxpayers and their advisers want the Indian government to clarify a number of issues including indirect share transfers in their 2015 budget on February 28.
By Sophie Ashley
February 17 2015
This content is from: Australia

ATO says ECAP programme is only in pilot stages and dismisses claims it would aid tax c...

The Australian Taxation Office (ATO) has been accused of pushing for big corporations to conduct their own tax audits. Negative comments in the media and statements from alleged employees claim the ATO’s efforts to re...
By Sophie Harding
February 13 2015
This content is from: Direct Tax

G20 ministers maintain support for BEPS agenda

Work on the G20 / OECD base erosion and profit shifting (BEPS) project has entered a new phase with the presentation of implementation guidance to a meeting of G20 finance ministers this week.
By Ralph Cunningham
February 13 2015
This content is from: United States

Hasbro agrees to pay Mexican SAT $4.38 million over tax avoidance claims

A spokesperson for US toy company Hasbro announced the company had agreed to pay the Mexican tax authorities (SAT) $65 million ($US 4.38 million) to settle tax avoidance claims. Hasbro is unlikely to be the only multi...
By Sophie Harding
February 11 2015
This content is from: Hong Kong SAR

Hong Kong shows eagerness to provide tax certainty with conclusion of first bilateral A...

Hong Kong’s Inland Revenue Department (IRD) has concluded its first bilateral advance pricing agreement (APA) with the Japanese tax authorities. The APA highlights the IRD’s willingness to cooperate with other countri...
By Sophie Harding
February 10 2015
This content is from: France

French oil company Total to close all tax haven subsidiaries in bid to promote transpar...

French oil company Total has announced plans to close subsidiaries in tax havens in a bid to prove it is making conscious efforts to clean up its tax policy. However, it remains to be seen whether Total’s intentions a...
By Sophie Harding
February 06 2015
This content is from: United States

OECD will update G20 finance ministers on BEPS project implementation next week

G20 finance ministers will hear about the OECD's three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10).
By Ralph Cunningham
February 06 2015
This content is from: Transfer Pricing

PAC report makes an example of PwC and urges HMRC to take a more active role in challen...

The Public Accounts Committee (PAC) released a report on tax avoidance, focusing primarily on tax arrangements between pharmaceutical company Shire and PwC. PAC’s insistence on making an example of PwC throughout the ...
By Sophie Harding
February 06 2015
This content is from: Belgium

New wave of transfer pricing audits in Belgium

This week, almost 200 taxpayers in Belgium received a detailed information request regarding their transfer prices.
By ITR Correspondent
February 06 2015
This content is from: Spain

Amendments to TP rules and the proposed introduction of CbCR suggest greater alliance b...

The Spanish government recently changed its transfer pricing rules regarding documentation requirements and penalties. These amendments show Spain is aligning itself more closely to OECD guidelines.
By Sophie Harding
February 04 2015
This content is from: Belgium

EC announces in-depth state aid investigation of Belgian excess profit ruling system

Yesterday the European Commission (EC) published a press release that it will further conduct an in-depth state aid investigation into the so-called Belgian excess profit rulings system.
By ITR Correspondent
February 04 2015
This content is from: United States

WTP Advisors’ add to transfer pricing team
February 04 2015
This content is from: India

LG awaits Delhi High Court ruling on taxation of marketing intangibles

Indian tax authorities have said that businesses spending higher than average on advertising, marketing, and promotions (AMP) expenses are creating marketing intangibles for related foreign enterprises and are therefo...
By Meredith McBride
February 03 2015
This content is from: India

Relief for taxpayers as Indian authorities instructed to follow Vodafone ruling in simi...

The Central Board of Direct Taxes (CBDT) has told Indian authorities to follow the principles outlined in the Vodafone case, in a move which will bring some certainty to the sub-continent.
By Joe Stanley-Smith
February 02 2015
This content is from: India

India’s CBDT asks ITAT and DRP to apply Vodafone ruling to similar transfer pricing cases

The Central Board of Direct Taxes (CBDT) has requested that Income Tax Appellate Tribunals (ITAT) and dispute resolution panels (DRP) apply the principle behind the Bombay High Court’s Vodafone ruling for similar tran...
By Sophie Harding
February 02 2015
This content is from: France

New French TP provisions call for tightening up of documentation but should lower audit...

France recently enacted transfer pricing provisions detailing penalties taxpayers can incur for noncompliance regarding documentation requirements. A regularisation procedure has also been formally implemented which s...
By Sophie Harding
February 02 2015
This content is from: Indonesia

New APA regulation released in Indonesia

The release of the Indonesian Ministry of Finance’s regulation Number 7/PMK.03/2015 (PMK-07) on the implementation of advanced pricing agreements (APA) is welcome news for Indonesian taxpayers that currently have an A...
February 02 2015
This content is from: Transfer Pricing

BEPS feedback highlights a lack of taxpayer confidence in the OECD's work on double tax...

Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dis...
February 02 2015

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