This content is from: Transfer Pricing Why investors are pushing for transparent tax planning The transparency of multinationals’ tax practices is a growing concern for investors because reputational damage from transfer mispricing can negatively affect share prices. By Joelle Jefferis November 26 2015
This content is from: Transfer Pricing OECD debated necessity of cost contribution chapter in BEPS In an interview with TPWeek, Andrew Hickman, head of the OECD’s transfer pricing unit, said the OECD debated whether a chapter on cost contribution arrangements was necessary in the final BEPS guidance released last m... By Sophie Ashley November 25 2015
This content is from: Transfer Pricing How OECD’s Andrew Hickman is managing the final BEPS guidance Andrew Hickman, head of the OECD’s transfer pricing unit, has been responsible for producing a large proportion of the OECD’s final BEPS guidance. By Sophie Ashley November 24 2015
This content is from: Italy Negotiating transfer pricing and customs value As international transfer pricing activities attract even more scrutiny, more attention is also being paid to customs regimes, and how they contribute to the transfer price. By ITR Correspondent November 24 2015
This content is from: India Why taxpayers see the TATA ruling as a breakthrough for Indian TP disputes In a transfer pricing dispute between TATA Consultancy Services and the deputy commissioner of income tax (DCIT) the Income Tax Appellate Tribunal (ITAT) has ruled that assessment officers (AO), should use their own m... By Joelle Jefferis November 24 2015
This content is from: Transfer Pricing How MAP is slowing down and disappointing taxpayers Mutual agreement procedures (MAP) are in place to resolve double taxation disputes, however the time it takes to find a resolution has led to a worldwide backlog of cases. Transfer pricing practitioners discuss their ... By Joelle Jefferis November 19 2015
This content is from: United Kingdom How small businesses can adopt multinational tax practices Small business owners in a British town have joined together to try to emulate multinational tax practices. By Joelle Jefferis November 17 2015
This content is from: United Kingdom New TP partner at KPMG Manchester By Joelle Jefferis November 13 2015
This content is from: Spain Spanish High Court rules in favour of Dutch Bank The Spanish High Court (AN – Audiencia Nacional) has ruled the Spanish authorities’ adjustment of Dutch Bank’s transfer pricing methods was wrong, stating that the OECD 2008 Model Tax Convention could not apply to doc... By Joelle Jefferis November 12 2015
This content is from: Vietnam More audits expected as Vietnam establishes dedicated TP inspection department The General Department of Taxation (GDT) in Vietnam has established a Transfer Price Inspection Department, a step that continues the authorities’ recent focus on transfer pricing activity. By Joelle Jefferis November 12 2015
This content is from: United Kingdom HMRC initiating fewer transfer pricing reviews HM Revenue & Customs (HMRC) has confirmed it is initiating fewer transfer pricing review cases with corporate entities in a Freedom of Information Act (FOIA) request submitted by TPWeek. By Sophie Ashley November 10 2015
This content is from: Ireland Pascal Saint-Amans against patent boxes: The next step for IP regimes Pascal Saint-Amans discussed the OECD’s dislike for patent box regimes at a Thomson Reuters news event last week. By Joelle Jefferis November 10 2015
This content is from: United States US to implement country by country reporting for 2016 The US is moving towards implementing country-by-country-reporting (CbCR) with the first reports likely to be required for the 2016 tax year. By Joelle Jefferis November 05 2015
This content is from: Transfer Pricing LONG READ: dispute resolution in BEPS – the good, the bad and the absent BEPS Action 14 makes great reading for fans of MAP, but fails to explore alternative dispute resolution (ADR) as much as some taxpayers had hoped. By Joe Stanley-Smith November 05 2015
This content is from: Brazil How Brazil is cherry picking BEPS recommendations Brazil, as a non-OECD member, seems to be cherry picking the BEPS recommendations that suit its regime, rather than accepting the full package. By Joelle Jefferis November 03 2015
This content is from: European Union Taxpayers must act now to manage implications of EU auditor independence regulations The EU has approved legislation which imposes mandatory audit firm rotation and restrictions on non-audit services to public interest entities (PIE). By Sophie Ashley November 03 2015