Transfer Pricing

Archive: Transfer Pricing

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Chile tax reform changes transfer pricing rules on related parties

Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.
By Gregorio Martínez

& PwC Chile
May 30 2018
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Chile tax reform changes transfer pricing rules on related parties

Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.
By ITR Correspondent
May 30 2018
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Transfer pricing aspects of restructuring: A Dutch case

Rachit Agarwal and Jian-Cheng Ku of DLA Piper discuss the transfer pricing aspects of a business restructuring within a multinational group, referencing a recent high-stakes Dutch court case.
By ITR Correspondent
May 30 2018
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Swedish interpretations of BEPS Actions 8-10

Annika Lindström and Maria Andersson of KPMG discuss how BEPS Actions 8 to 10 are being interpreted in relation to transfer pricing in Sweden.
By ITR Correspondent
May 30 2018
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Ireland: High Court to hear case on deductibility of foreign withholding tax

The Irish Revenue Commissioners (Revenue) were successful in arguing before the Appeal Commissioners that no general trading deduction should be available for excess foreign tax incurred on royalties where an Irish ta...
By Brian Doohan

& Matheson

& Olivia Long
May 29 2018
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Germany: Post-BEPS challenges and transfer pricing solution requirements in central man...

In the first of a series on transfer pricing technical challenges and solutions to changing economic and regulatory environments for global multinationals, this article focuses on the remuneration of top management fu...
By Nera

& Philip de Homont

& Yves Hervé
May 29 2018
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IRS issues APA statistics for 2017

Mark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017.
By Cameron Taheri

& KPMG US

& Mark Martin
May 29 2018
This content is from: United States

US intervention in Apple state aid case eyed critically

The Court of Justice of the European Union has upheld a decision that the US will not be allowed to intervene in Apple’s Irish state aid case. US tax professionals debate whether the US government had a strong case fo...
By Lena Angvik
May 25 2018
This content is from: United Kingdom

Chartered Institute of Taxation appoints new presidency

The Chartered Institute of Taxation, the UK professional body for taxation, has appointed Ray McCann to president, Glyn Fullelove to deputy president, and Peter Rayney to vice president.
By Lena Angvik
May 25 2018
This content is from: Netherlands

Netherlands favours certain DEMPE functions in new transfer pricing decree

The Dutch Ministry of Finance has released a new transfer pricing decree that gives more weight to the development and enhancement of intangibles in cost and profit allocation, contrasting with the OECD Transfer Prici...
By Lena Angvik
May 24 2018
This content is from: United Kingdom

Deloitte UK appoints Sophie Brown to transfer pricing head

Sophie Brown has been appointed head of transfer pricing for Deloitte UK in London.
By Lena Angvik
May 23 2018
This content is from: European Union

Report claims McDonald’s hides from EU tax scrutiny

A new trade union report slams McDonald’s for setting up a new corporate structure with companies in the UK, Delaware and the Caribbean and claims the company’s intention is to escape tax scrutiny in the EU.
By Lena Angvik
May 22 2018
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Italy refines transfer pricing methodology

A new decree replaces Italy’s previously established hierarchy of transfer pricing methods, and aligns the country further with the OECD's guidelines. TP Week’s correspondents in Italy, Antonella Della Rovere and Fede...
By Antonella Della Rovere

& Crowe Valente/Valente Associati GEB Partners

& Federico Vincenti
May 21 2018
This content is from: Austria

European Tax Awards 2018: Winners announced

Europe’s leading tax firms dominated this year’s European Tax Awards through innovation and outstanding tax controversy management.
By Sonja Caymaz
May 18 2018
This content is from: India

Discovery’s Indian head of tax Umang Dhingra talks dispute resolution

Discovery Communications India’s head of tax, Umang Dhingra, talks to TP Week about how he led the company through nine years of demanding litigation on a permanent establishment case and how the dispute was resolved ...
By Lena Angvik
May 18 2018
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Analysing control over risk in relation to intangible assets

The Australian Taxation Office (ATO) has identified the use of intangible assets by multinational corporate groups as a key compliance risk for 2018 and has put extra effort into transfer pricing issues involving inta...
By ITR Correspondent
May 17 2018
This content is from: Australia

Asia Tax Forum 2018 special: BEPS actions reverberate through Asia

The taxation of the digital economy and how taxpayers and tax authorities cope with the roll-out of new transfer pricing regimes in the Asia Pacific region dominated the agenda at TP Week and International Tax Review’...
By Sonja Caymaz
May 17 2018
This content is from: European Union

EU directive raises uncertainty over tax avoidance reporting duty

An EU directive will require intermediaries to report certain cross-border tax arrangements, but advisers point to client confidentiality and privacy laws, and some say the reporting burden will still rest with the ta...
By Lena Angvik
May 15 2018
This content is from: Australia

Australian senate to probe healthcare sector in tax avoidance inquiry

Australia has taken allegations of profit shifting in the aged-care sector seriously. After last week’s allegations of offshore profit shifting through stapled structures, Australian nursing homes and other aged-care ...
By Lena Angvik
May 11 2018
This content is from: Czech Republic

Transfer pricing dominates demand for MAP

Transfer pricing has become the main cause of lengthy MAP cases, OECD reports show. The OECD peer reporting mechanism, however, may drive change in tax authorities’ efforts towards resolving MAP cases.
By Lena Angvik
May 10 2018
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EU digital tax will require changes to OECD transfer pricing guidelines

The OECD and the European Commission recently released papers on the taxation of the digital economy, reflecting the political desire in some countries for measures to address perceived tax imbalances. Alison Lobb and...
By ITR Correspondent
May 10 2018
This content is from: Australia

Australian healthcare sector in crosshairs for alleged tax avoidance

Some of Australia’s biggest nursing homes have come under fire in a new report for allegedly shifting profits offshore. The Australian Treasury is strengthening thin capitalisation laws to tackle tax avoidance through...
By Lena Angvik
May 04 2018
This content is from: Australia

Asia Tax Awards 2018: Winners announced

Firms, individuals and companies across the Asia-Pacific region shared prizes at the Asia Tax Awards in Singapore on May 3 2018.
By Anjana Haines
May 03 2018
This content is from: European Union

EU digital sales tax faces uphill battle

The European Commission’s digital tax proposals, aimed at making digital companies pay more tax, are rapidly losing support from key jurisdictions such as Germany. The controversial digital sales tax is now looking in...
By Lena Angvik
May 03 2018
This content is from: European Union

LuxLeaks whistleblower: EU protection should be widened

The LuxLeaks whistleblowers have welcomed a new EU proposal for protection for people who report tax evasion and tax avoidance. They told TP Week its scope should be widened as much as possible.
By Lena Angvik
May 02 2018
This content is from: United Kingdom

DLA Piper UK promotes two to transfer pricing partners

DLA Piper has promoted eight tax lawyers to its partnership, including two transfer pricing specialists in the firm’s London office.
By Lena Angvik
May 02 2018

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