This content is from: China China wants local version of BEPS China’s State Administration of Taxation (SAT) has released a discussion draft circular, which would see the implementation of the OECD three-tier reporting style of county-by-country-reporting (CbCR) as well as the m... September 30 2015
This content is from: Denmark Europe aims to lead the world in transfer pricing legislation The OECD has been leading the discussions on global transfer pricing issues through its BEPS project but, as this draws to a close, the implementation of BEPS-influenced legislation is producing different interpretati... September 30 2015
This content is from: Sponsored Americas Tax Awards 2015 Top honours at this year's Americas Tax Awards went to Deloitte, Baker & McKenzie and Skadden Arps Slate Meagher & Flom. By Salman Shaheen September 28 2015
This content is from: Global The Brockman brief: Performance review: The OECD’s reputation The curtain is drawing to a close on the final OECD BEPS recommendations, while the OECD actors and supporting staff anxiously await reaction from the audience. This month’s Brockman brief runs the rule over the OECD’... September 28 2015
This content is from: Sponsored Middle East: PE formation in KSA: Operating across borders The Saudi Arabian Department of Zakat and Income Tax (DZIT) has issued internal guidelines to all its branches and divisions for processing withholding tax (WHT) refund claims for non-residents. By ITR Correspondent September 28 2015
This content is from: Global License fees determined by the ‘willingness-to-pay’ In the second of a series of updates on intangibles valuation and intellectual property (IP) assets, NERA principal Philip de Homont and affiliated consultant Alexander Voegele look at intangibles that allow companies... September 28 2015
This content is from: United States Tax and investment: UNCTAD’s contribution to the BEPS debate The debate about international tax reform has received a valuable boost from the UN’s annual investment report, argues Jeffrey Owens of Vienna University of Economic and Business. September 28 2015
This content is from: United States Why tax authorities also need to upgrade their technology for CbCR Meeting new reporting requirements needs technology planning for taxpayers and revenue authorities alike, a panel at International Tax Review and TPWeek’s Global Transfer Pricing Forum in Washington DC concluded. September 27 2015
This content is from: India Oil price downturn brings increased transfer pricing audits In the second half of 2014 oil prices sharply fell. One year on and the markets seem unlikely to return to the former high, at least in the next few years. September 21 2015
This content is from: Norway The impact of BEPS on indirect taxes in Norway Espen Qvist and Trond Ingebrigtsen of PwC Norway provide an overview of issues being tackled as part of the OECD’s base erosion and profit shifting (BEPS) project which are having an impact on Norwegian indirect tax p... September 21 2015
This content is from: India Infogain’s profit-split method approved by ITAT The income tax appellate tribunal (ITAT) in Delhi upheld Infogain India’s appeal against the deputy commissioner of income tax’s (DCIT) TP adjustment. ITAT found that the use of the profit split method (PSM) was valid... September 20 2015
This content is from: European Union Netherlands introduces CbCR The Netherlands has become the latest country to introduce draft legislation for country-by-country reporting (CbCR) alongside requirements for a master file and a local file. September 20 2015
This content is from: United States Deloitte wins again at Americas Tax Awards 2015; Big awards for Baker and Skadden too Top honours at this year's Americas Tax Awards went to Deloitte, Baker & McKenzie and Skadden Arps Slate Meagher & Flom. By Ralph Cunningham September 17 2015
This content is from: United States IRS significantly changes competent authority application The IRS has published final changes for taxpayers applying for competent authority (CA) assistance. An IRS official and a former US Competent Authority explain what this means for taxpayers. September 13 2015
This content is from: Transfer Pricing Prepare for BEPS: How to find evidence of independent party deal structures It is no longer sufficient to only support the arm’s-length pricing of transactions. Companies must now validate the structure of their intercompany transactions against evidence from independent party transactions. September 13 2015
This content is from: United Kingdom Why smaller companies are at a greater risk of TP adjustment from HMRC Through analysing HM Revenue and Customs’ (HMRC) “tax under consideration” figures it appears HMRC is turning its attention to medium sized companies, after years of putting large businesses’ transfer pricing activiti... September 08 2015
This content is from: United States How public reporting of corporate tax affairs is becoming more likely A fundamental sticking-point of country-by-country reporting (CbCR) is that companies’ tax affairs could be published in the public sphere. This is causing a great deal of distress for multinationals concerned about c... September 08 2015
This content is from: United States Managing the transfer pricing of intangibles in the oil and gas sector Intangible assets in the oil and gas industry have become incredibly valuable. Taxpayers need to understand how to manage compliance to mitigate their transfer pricing risks. September 07 2015
This content is from: India Why India rejected the OECD’s mandatory arbitration plans India has rejected the OECD’s plans for mandatory arbitration and, despite the country’s non-member status, the proposal has now been dropped. By Sophie Ashley September 01 2015
This content is from: United States IRS revamps APA procedures The IRS has finalised changes to its APA procedures, first proposed in November 2013. The changes include greater disclosure requirements for taxpayers but many changes simply formalise existing practices. September 01 2015
This content is from: Transfer Pricing Angola focusing on large taxpayers’ transfer pricing Angolan tax authorities are notifying large taxpayers that have failed to file transfer pricing documentation they will be fined. September 01 2015
