Transfer Pricing

Archive: Transfer Pricing

This content is from: Transfer Pricing

MNEs pursue APAs to counter reputational risk

Heads of tax are turning to bilateral advance pricing agreements to help prevent reputational risk from accusations of sweetheart tax deals between taxpayers and tax authorities.
By Lena Angvik
June 29 2018
This content is from: Australia

Exclusive: ATO reveals transfer pricing on priority list

Intellectual property transfers, related-party debt, offshore marketing hubs and hybrid mismatches are some of the areas the Australian Taxation Office is focusing on now, Deputy Commissioner Jeremy Hirschhorn tells T...
By Lena Angvik
June 27 2018
This content is from: United States

Multinationals face transfer pricing risks by delaying ATAD assessment

With only six months left before the wide-ranging EU’s Anti-Tax Avoidance Directive provisions enter into force, multinationals are advised to weigh compliance and controversy risks for cross-border tax structures acr...
By Lena Angvik

& Sonja Caymaz
June 22 2018
This content is from: United Kingdom

Duff & Phelps appoints European leader of global transfer pricing

Ted Keen has joined Duff & Phelps as the European leader for the firm’s global transfer pricing practice.
By Lena Angvik
June 21 2018
This content is from: India

Google India decision signals possible double taxation

Google India is appealing a court decision that found payments made to Google Ireland should be classified as royalties. Digital companies operating in India fear the negative impact from the decision that could trigg...
By Lena Angvik
June 20 2018
This content is from: United States

Bill Sample: Profit split should be last resort for digital economy

The EU’s proposal for taxing the digital economy isn’t sitting well with American businesses. Bill Sample, former VP of tax at Microsoft and chair of the US Council for International Business, tells TP Week why the EU...
By Lena Angvik
June 18 2018
This content is from: European Union

CJEU decision allows for deviation from arm’s-length principle

The Court of Justice of the European Union decided in the Hornbach-Baumarkt case that deviations from the arm’s-length principle can be permissible in certain circumstances. The ruling is expected to have a significan...
By Lena Angvik
June 14 2018
This content is from: United States

Financial transactions guidance to counter transfer pricing disputes

An OECD discussion draft on intra-group financial transactions is slated for release in July. Stakeholders hope the OECD can provide some much-needed principles on financial transactions such as intra-group guarantees...
By Lena Angvik
June 12 2018
This content is from: United Kingdom

KPMG recruits from HMRC

Former HMRC employee Gareth Hann has joined KPMG’s Edinburgh office as a transfer pricing director.
By Lena Angvik
June 11 2018
This content is from: Sponsored

Canada reinforces substance requirements in transfer pricing

Canada announced certain international tax changes in its 2018 federal budget. TP Week’s correspondents Norma Kraay and Phil Fortier of Deloitte in Canada consider commentary indicating a continued focus on transfer p...
By ITR Correspondent
June 08 2018
This content is from: United States

US corporate tax rate has not sparked race to the bottom, OECD says

The US tax reform has been blamed for triggering a new race to the bottom for corporate tax rates. But the US is in line with OECD recommendations and has merely “hopped to the middle”, says the OECD’s Grace Perez-Nav...
By Lena Angvik
June 07 2018
This content is from: United States

OECD conference debates value creation in taxation of the digital economy

The 2018 OECD International Tax Conference in Washington DC on June 4-5 debated proposals for taxing the digital economy and the concept of user participation and value creation.
By Lena Angvik
June 06 2018
This content is from: Sponsored

Transfer pricing and double taxation: Italy’s downward adjustment procedure

The Italian Revenue Agency issued new rules regarding the requirements and procedure for the pursuit of downward adjustment of taxable income. TP Week’s Italy correspondents Antonella Della Rovere and Federico Vincent...
By Antonella Della Rovere

& Crowe Valente/Valente Associati GEB Partners

& Federico Vincenti
June 05 2018
This content is from: Transfer Pricing

Transfer pricing documentation boosts interest in database services

Taxpayers and advisers are exploring external databases to save time on finding reliable comparables for arm’s-length calculations and assist with transfer pricing documentation.
By Lena Angvik
June 01 2018

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