Transfer Pricing

Archive: Transfer Pricing

This content is from: Chile

Chile: New concept of permanent establishment

The Chilean IRS issued Circular Letter No 57 on December 7 2017 regarding the concept of permanent establishment (PE) for purposes of obtaining a Chilean identification number when non-resident, non-domiciled individu...
By PwC Chile

& Santiago López
January 30 2018
This content is from: Sponsored

Hong Kong: Hong Kong see new tax reforms to kick start 2018
By Curtis Ng

& KPMG China

& Lewis Lu
January 30 2018
This content is from: Brazil

Brazil: Withholding tax rules on license to distribute or commercialise software

The federal Brazilian tax authorities (RFB) published a declaratory act regarding the withholding tax on payments abroad for a license to distribute or commercialise software.
By Fernando Giacobbo

& Mark Conomy

& PwC Brazil
January 30 2018
This content is from: Sponsored

Russia: Russia adopts OECD BEPS 13 rules on three-tiered approach for transfer pricing ...
By Ilarion Lemetyuynen

& KPMG Russia
January 30 2018
This content is from: Sponsored

Poland: Amendment to CIT Act – transfer pricing modifications

Revolutionary modifications in transfer pricing (TP) regulations, introduced by the Corporate Income Tax (CIT) law amendment valid since January 1 2017, may be followed by more changes binding from 2018.
By Magdalena Marciniak

& MDDP
January 30 2018
This content is from: Sponsored

New Zealand: High Court invalidates information request issued at request of foreign ta...

In a recent decision, the New Zealand High Court considered a challenge to the validity of requests for information made by New Zealand Inland Revenue at the request of the Korean National Tax Service (Korea).
By Brendan Brown

& Russell McVeagh

& Tim Stewart
January 30 2018
This content is from: Sweden

Swedish court rejects hindsight in arm’s-length pricing

A Swedish court has ruled on timelines for information used in benchmarking searches in a case involving The Absolut Company, which produces Absolut Vodka. The court concluded, supported by the OECD Transfer Pricing G...
By Lena Angvik
January 29 2018
This content is from: Ukraine

Ukrainian companies modify cross-border supply chains to avoid transfer pricing

Ukrainian law requires transfer pricing controls on transactions with foreign companies located in black-listed low-tax jurisdictions, regardless of related party status. Companies in Ukraine may be increasingly limit...
By Lena Angvik
January 26 2018
This content is from: Denmark

APAs lose lustre amid increasing number of disputes

The Danish tax authority’s focus on transfer pricing has resulted in high levels of controversy over the past few years, especially in permanent establishment cases. Companies are now re-evaluating the usefulness of A...
By Lena Angvik
January 25 2018
This content is from: Finland

Borenius names two new partners

Finnish law firm Borenius has strengthened its tax practice with the promotion of Einari Karhu and Heikki Wahlroos to partners.
By Lena Angvik
January 25 2018
This content is from: United States

US tax reform set to increase number of CFCs and transparency risk

The US tax reform introduces changes to Subpart F stock attribution rules that are expected to result in the formation of many new controlled foreign corporations. However, the amendments leave room for interpretation...
By Lena Angvik
January 22 2018
This content is from: United States

Foreign MNEs seek tax certainty through APAs after US tax reform

Among the first to conclude an APA with the IRS, Indian IT company Infosys is paving the way for MNEs to seek certainty on transfer pricing issues such as attribution of profits to US operations in the wake of US tax ...
By Lena Angvik
January 18 2018
This content is from: Argentina

Argentina amends transfer pricing guidelines for commodity transactions

Argentina’s tax reform changes the paradigm of transactions carried out through international intermediaries, including the ‘sixth method’. Economist and transfer pricing specialist Tomás Smudt reports from Argentina ...
By ITR Correspondent
January 17 2018
This content is from: United Kingdom

Heather Self joins Blick Rothenberg

Accounting, tax and advisory practice Blick Rothenberg has appointed Heather Self as a corporate tax partner in London.
By Lena Angvik
January 16 2018
This content is from: Australia

Final days to enter for the Asia Tax Awards 2018

The deadline to submit for the Asia Tax Awards 2018 is fast approaching. Companies, firms and individuals working in jurisdictions across the Asia Pacific region should enter now.
By Anjana Haines
January 15 2018
This content is from: Belgium

CJEU case on Hornbach could set arm’s-length precedent

The outcome of the CJEU’s case on German DYI-chain Hornbach could restrict many EU multinationals in countries with similar legislation.
By Lena Angvik
January 12 2018
This content is from: European Union

CJEU ruling may cause rift between transfer pricing and customs valuation

The recent CJEU ruling on Hamamatsu Photonics Germany may increase the administrative and compliance burden for related-party trade into the EU. Interpretations of the ruling by tax advisers indicate that transfer pri...
By Sonja Caymaz
January 09 2018
This content is from: Belgium

Technical issues give rise to CbCR deadline extensions

Despite the vast majority of multinationals being ready to file their country-by-country reports by the end of the year, several countries chose to defer the filing deadline for a variety of reasons, including difficu...
By Lena Angvik
January 04 2018
This content is from: Netherlands

Houthoff adds Paulus Merks to expanding tax team

Houthoff, the independent law firm headquartered in the Netherlands, expects to double its tax team by the end of 2018, starting with the hiring of Paulus Merks as a partner in Amsterdam.
By Lena Angvik
January 03 2018
This content is from: United States

2018 outlook for landmark transfer pricing disputes

TP Week rounds up some of the most influential transfer pricing disputes from the past year, and explores how they could evolve this year or what repercussions they could have for similar cases.
By Lena Angvik
January 02 2018

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