This content is from: Transfer Pricing Schoeneborn joins EY from Merck Dr. Frank Schoeneborn joins EY as a partner in EMEIA Tax Centre focusing on intercompany effectiveness and operational transfer pricing. March 27 2015
This content is from: Transfer Pricing OECD paper on risk and re-characterisation could threaten arm’s-length principle says i... Industry representatives are concerned about the continued viability of the arm’s-length principle in light of the OECD’s paper on risk and re-characterisation, released as part of the base erosion and profit shifting... By Sophie Ashley March 27 2015
This content is from: United States Transfer Pricing Focus 2015 now available Taxpayers and leading advisers provide insights on BEPS and transfer pricing from Latin and North America to China. March 27 2015
This content is from: Transfer Pricing New German regulations on allocation of profits to permanent establishments The Upper House of the German Parliament (Bundesrat) approved the regulations on the application of the arm’s-length principle to permanent establishments (PE regulations), which follow the authorised OECD approach (A... By ITR Correspondent March 27 2015
This content is from: China China’s SAT issues regulations on outbound service payments as part of crackdown on tax... China’s State Administration of Taxation (SAT) recently issued a notice regarding payments involving related offshore parties. China has openly declared its plans to crackdown on tax evasion, so the issuing of new reg... By Sophie Harding March 26 2015
This content is from: Switzerland Pascale Colin: Defining challenges for today's group tax manager Matthew Gilleard talks with Pascale Colin, group tax manager at EFG Bank, about the role of the tax director, her journey in getting there, and operating successfully in a rapidly-evolving Swiss, European and global t... By Matthew Gilleard March 25 2015
This content is from: India Taxpayers welcome Delhi High Court’s decision to strike out bright-line test for AMP ex... The Delhi High Court issued a significant ruling concerning the taxation of advertising, sales, and marketing promotions (AMP) expenses. By Meredith McBride March 25 2015
This content is from: Global TP risk determination: Transparency and mutuality This month, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, runs the rule over issues of transfer pricing risk determination, focusing on transparency... By default\Anonymous March 25 2015
This content is from: China Practical considerations for Chinese withholding tax on cross-border service transactions The potential Chinese tax implications of the provision of cross-border services into China are as numerous as they are confusing. Scott Heidecke and Flora Luo of Nexia International member firm Nexia TS (Shanghai) di... March 25 2015
This content is from: Australia Rio Tinto fears OECD’s BEPS project will discriminate against multinationals and harm i... Rio Tinto’s “taxes paid” report for 2014 revealed the company paid $ 7.1 billion worth of taxes and royalties globally. The report also voiced Rio Tinto’s concerns over the OECD’s base erosion and profit shifting (BEP... By Sophie Harding March 24 2015
This content is from: India Taxpayers laud Delhi High Court for striking out bright-line test for AMP expenses The Delhi High Court has delivered a major ruling regarding the taxation of advertising, sales, and marketing promotions (AMP) expenses. By Meredith McBride in Hong Kong March 23 2015
This content is from: European Union EC reveals tax transparency measures and promotes automatic exchange of information as ... On March 18, the European Commission (EC) released its Tax Transparency Package which it hopes will serve as a tool for “healthier” tax competition and help member states recognise illicit tax practices. By Ralph Cunningham March 19 2015
This content is from: Italy Italian Supreme Court rules TP irregularities must be substantiated with clear avoidanc... In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent. The Supreme Court ruled that if there is no clear econo... By ITR Correspondent March 19 2015
This content is from: Denmark SKAT’s aggressive approach to transfer pricing leaves taxpayers fearing an anti-busines... Danish tax authority, SKAT, collected DKK 20 billion ($2.9 billion) in tax adjustments in 2014 by challenging 76 companies’ transfer pricing arrangements. The agency’s aggressive tax policy has been widely criticised ... By Sophie Harding March 18 2015
This content is from: India Release of APA roll-back provisions in India welcome news for taxpayers India’s long-awaited advance pricing agreement (APA) roll-back provisions have been released. This will come as welcome news to taxpayers who criticised the government’s 2015 Budget for overlooking important transfer ... By Sophie Harding March 17 2015
This content is from: India Tax demand against Cairn contradicts India’s 2015 Budget aim to create investor-friendl... The Income-Tax Department (I-T Department) has issued Cairn Energy (Cairn) with a Rs. 10,247 ($1.6 billion) tax demand over its transfer of assets to Cairn India. The tax demand draws similarities with Vodafone and su... By Sophie Harding March 17 2015
This content is from: India Rahul Mitra joins KPMG India from PwC Rahul Mitra has joined KPMG India (BRS & Associates is the affiliated chartered accountant firm) as a partner in the tax and transfer pricing practice and national leader of dispute resolution and litigation for direc... March 17 2015
This content is from: United States Disparity between the US and Brazil’s approach to royalties increases risk of double ta... As a result of Brazil’s unique policy to prevent erosion of the tax base, companies often face double taxation. By ITR Correspondent March 13 2015
This content is from: Italy Italy’s patent box regime should escape criticism because of alignment with OECD nexus ... Italy has introduced a patent box regime based on the OECD’s nexus approach, which will grant exemptions for profits derived from certain intangible assets for corporate and regional tax purposes. Italy’s alignment wi... By Sophie Harding March 12 2015
This content is from: Switzerland Switzerland Focus 2015 now available Leading advisers update you on the latest developments in Switzerland. March 12 2015
This content is from: United Kingdom HMRC’s 2013-14 transfer pricing statistics show increase in time taken to resolve TP cases HM Revenue & Customs (HMRC) recently released its transfer pricing statistics for 2013-14. While HMRC collected almost twice as much in additional taxes compared with 2012-13, the time taken to resolve advance pricing... By Sophie Harding March 11 2015
This content is from: Australia Australian opposition leader’s thin capitalisation proposals met with strong criticism Australia’s opposition Labor party has received strong criticism from business leaders and advisers over its plans to increase the tax burden on corporations by changing the thin capitalisation threshold. By Meredith McBride March 10 2015
This content is from: India How India is striving to attract your company's investment through transfer pricing mea... Following on from the Indian budget last month and various significant developments on the disputes scene, TPWeek thinks it is a good time to put together a Special Focus, bringing together its most recent reports. March 10 2015
This content is from: Transfer Pricing Total delivers on plans to promote tax transparency by publishing full list of subsidia... French oil company Total has delivered on its promise to publish a full list of its subsidiaries. The move shows Total is making significant efforts to promote transparency, but the list is just a drop in the ocean in... By Sophie Harding March 09 2015
This content is from: United Kingdom Duff & Phelps forms London based TP team Richard Newby, Shiv Mahalingham, Danny Beeton and Andrew Cousins have joined Duff & Phelps to form a London based transfer pricing team. March 05 2015
This content is from: United States Microsoft IRS transfer pricing case dismissed Microsoft and the Internal Revenue Service (IRS) have agreed to end their battle over documents used in transfer pricing audits of the tech company. By Sophie Harding March 04 2015
This content is from: India Indian finance minister keeps transfer pricing at “arm’s-length” in 2015-16 budget speech Taxpayers think the 2015 Indian budget, announced on Saturday, did not focus strongly enough on transfer pricing and have described it as “disappointing”. By Sophie Harding March 04 2015
This content is from: European Union How HMRC is tackling tax arrangements similar to Starbucks’ The Public Accounts Committee (PAC) met last month to ask HM Revenue & Customs (HMRC) about its efforts to curb tax avoidance, including how HMRC has developed its transfer pricing approach to counteract tax arrangeme... By Sophie Ashley March 03 2015
This content is from: Canada Timing of Canada Revenue Agency’s TPM-16 on multiple year data “odd” in light of pendin... The Canada Revenue Agency (CRA) has released transfer pricing memorandum 16 (TPM-16), which formalises guidance on multiple year data. While the guidance is far from ground-breaking, the timing of its release appears ... By Sophie Harding March 03 2015
This content is from: Indonesia Indonesia wages war on corporate tax avoidance through transfer pricing The director-general of taxes in Indonesia has confirmed government plans to clampdown on corporate tax avoidance facilitated by transfer pricing. By Sophie Harding March 03 2015
