This content is from: Sponsored TP in China: SAT tapping into the tax big data paradise Transfer pricing continues to be one of the Chinese State Administration of Taxation’s key focus areas, write Cheng Chi, Rafael Triginelli Miraglia and Choon Beng Teoh of KPMG. New policies and methodologies are being... By ITR Correspondent August 30 2018
This content is from: United States Coca-Cola faces big US tax bill if Medtronic loses dispute Coca-Cola’s profit split method may result in the soft drinks giant having to pay a $3.3 billion tax bill if the US Tax Court decides to reverse its earlier decision on the Medtronic case. By Josh White August 29 2018
This content is from: Australia Asia Pacific – a harmonious interplay between transfer pricing and customs valuation? The rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writ... By ITR Correspondent August 28 2018
This content is from: Sponsored European Union: Public country-by-country reporting in the EU off the tracks, for now By Bob van der Made & PwC August 24 2018
This content is from: Sponsored Hong Kong: Hong Kong introduces new transfer pricing regime By Curtis Ng & KPMG Hong Kong & Lewis Lu August 24 2018
This content is from: Sponsored Germany: DEMPE analysis for CUP studies In TP audits around the world, tax authorities are starting to use the development, enhancement, maintenance, protection, and exploitation of intangibles (DEMPE) concept that was recently established by the OECD. By Nera & Philip de Homont & Yves Hervé August 24 2018
This content is from: Argentina Tax treaty developments in Argentina A new tax treaty between Argentina and Brazil came into force during the summer. By Ignacio Rodríguez & PwC Argentina August 24 2018
This content is from: Austria UK’s post-Brexit state aid structure to create conflict on tax rules The UK’s plans to remain aligned with European Union state aid rules after Brexit could put the Competition and Markets Authority (CMA) on a collision course with UK parliaments and taxpayers as it weighs in on tax ru... By Michael Scaturro August 23 2018
This content is from: Japan Update on Japanese transfer pricing 2018 Recent changes in the business environment and the financial situation of the Japanese government have affected the Japanese taxation environment and transfer pricing regulations, explain Jun Tanaka, Nobuhiro Tsunoda ... By ITR Correspondent August 23 2018
This content is from: Sponsored Canada issues advance pricing arrangement programme report Phil Fortier, Alex Evans, and Raf Sattar of Deloitte in Canada summarise the key aspects of Canada’s APA programme report for 2017, allowing taxpayers and tax practitioners to align expectations of the scheme with the... By ITR Correspondent August 21 2018
This content is from: United States US Tax Court told to reconsider Medtronic’s use of CUT method The US Tax Court will have to once again review whether Medtronic’s use of the comparable uncontrolled transactions (CUT) method complied with regulations after the Eighth Circuit Court referred the case back for deep... By Josh White August 20 2018
This content is from: Sponsored Fine-tuning the legislation for greater compliance Singapore has been increasing its focus on transfer pricing, explain Geoffrey K Soh, Felicia Chia and Jingyi Lee of KPMG, with yearly revisions of the TP guidelines as well as the adoption of country-by-county reporti... By ITR Correspondent August 16 2018
This content is from: United Kingdom UK tax advisers enter ‘growth mode’ as TP audits rise As the UK tax authority, HMRC, allocates more resources to tackling tax losses, tax advisers and taxpayers are raising their game to deal with TP audits and APAs that are taking longer than ever to conclude. By Anjana Haines August 16 2018
This content is from: India UK could take unilateral action on digital tax in 2018 budget The UK government might announce its own rules to tax the digital economy in the upcoming budget in autumn 2018 after ministers hint that they are considering their options. By Anjana Haines August 14 2018
This content is from: Sponsored First automatic CbC report exchanges to trigger tax authority risk assessments Alison Lobb and Christa Silverthorne of Deloitte take a look at the practical steps for large multinational groups to manage global tax authority enquiries following the automatic exchange of country-by-country (CbC) ... By ITR Correspondent August 13 2018
This content is from: United States US TP standards saved from disaster after court withdraws judgment The US Ninth Circuit Court’s withdrawal of its July 24 decision in Altera has prevented US transfer pricing rules from going into meltdown – for now. By Anjana Haines August 09 2018
This content is from: Germany First results of CbCR data exchange to be announced by year-end The Netherlands tax authority has told TP week that it plans to report on its findings from the exchanged country-by-country data by the end of 2018, with Ireland and Germany saying they will have details early next y... By Michael Scaturro August 07 2018
This content is from: Transfer Pricing Transfer pricing: Employees trigger value creation within MNEs Gautier Ciresa, transfer pricing manager at Technicolor, explains why employees are the true indicator of value creation within MNEs and how to determine their impact in a transfer pricing analysis. By ITR Correspondent August 06 2018
This content is from: Transfer Pricing Euromoney Legal Media Group Americas Rising Stars Awards – inaugural shortlist announced Euromoney Legal Media Group has announced the shortlist for its inaugural Americas Rising Stars Awards. By Anjana Haines August 03 2018
This content is from: Sponsored Mandatory electronic invoicing: Are you ready? Electronic invoicing will be mandatory for transactions from 2019, write Antonella Della Rovere and Filipa Correia of Crowe Valente/Valente Associati GEB Partners. Intercompany invoicing will also be affected by this ... By Antonella Della Rovere & Crowe Valente/Valente Associati GEB Partners & Filipa Correia August 02 2018
This content is from: European Union Taxpayers fearful of virtual PE rules Fear over double taxation has emerged as a key issue in the taxation of the digital economy debate. Corporate tax directors and advisers tackle the challenge a virtual permanent establishment will present and try to a... By Sonja Caymaz August 01 2018
