Transfer Pricing

Archive: Transfer Pricing

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Transfer pricing in Mexico: The upcoming challenges and opportunities

Simon Somohano and Isaac Manuel Ramirez Obeso of Deloitte discuss the tax implications of the new government’s fiscal agenda as President-elect Andrés Manuel López Obrador (AMLO) prepares to take office in December.
By ITR Correspondent
October 31 2018
This content is from: Brazil

Brazil: Tax authorities say French not-for-profit organisations subject to tax

Brazilian tax authorities have said that no relief should be granted for withholding tax on payment to foreign not-for-profit organisations under the Brazil-France double tax agreement (DTA).
By Fernando Giacobbo

& Mark Conomy

& PwC Brazil
October 31 2018
This content is from: United Kingdom

UK government announces digital services tax

UK Chancellor of the Exchequer Philip Hammond described the OECD’s progress to delivering a global solution to taxing the digital economy as “painfully slow” as he announces unilateral measures in his budget statement.
By Anjana Haines
October 29 2018
This content is from: Global

Companies risk high withholding taxes if MLI’s discretionary relief is denied

Businesses should not wait to examine the tax risks posed by the Multilateral Instrument (MLI), which could result in high domestic withholding taxes if the principal purpose test (PPT) is applied and discretionary re...
By Anjana Haines
October 26 2018
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Brazilian real devaluation will influence 2018 transfer pricing adjustments

The Brazilian presidential election and risks of currency devaluation may substantially affect the TP analysis of local taxpayers and increase eventual adjustments on import transactions.
By ITR Correspondent
October 25 2018
This content is from: Qatar

Transfer pricing has landed in the MENA region

Companies operating in the Middle East or North Africa need to be reviewing their TP obligations across the region now as an increasing number of countries implement new TP rules. Saudi Arabia is next.
By ITR Correspondent
October 25 2018
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TP rules in the Philippines: Still at a standstill?

Transfer pricing is on the radar again in the Philippines, reports Maria Carmela Peralta of KPMG. It’s too early to tell whether the lengthy discussions taking place will bear fruit and the Philippines will have somet...
By ITR Correspondent
October 25 2018
This content is from: United Kingdom

HMRC 'surprised' by taxpayer claims of 'abuse of power'

UK revenue authority, HM Revenue and Customs, has said it is “surprised” by claims made at a UK parliamentary hearing that it has become increasingly aggressive towards taxpayers.
By Anjana Haines
October 23 2018
This content is from: Chile

In praise of the Chilean tax authority

Training, expertise and the professional outlook of the transfer pricing team in the Chilean tax authority has resulted in a focused, successful and understanding TP unit that is willing to liaise with taxpayers and t...
By ITR Correspondent
October 18 2018
This content is from: Austria

The ITR European Tax Awards 2019: Submit now

Companies, firms and individuals can now enter for the International Tax Review European Tax Awards 2019.
By Anjana Haines
October 17 2018
This content is from: Sponsored

Mexico court rules against taxpayer in transfer pricing case

Mexico’s First Circuit Court has recently ruled against a taxpayer in a case involving two transfer pricing adjustments that will make it tougher for companies to comply with their domestic tax obligations on time.
By Deloitte Mexico

& Francisco Ruiz

& Ricardo Santoyo
October 16 2018
This content is from: United Kingdom

A UK digital tax risks unintended consequences for businesses

The UK is mulling a digital revenue levy that marks a significant departure from the arm’s length principle and risks income tax relief in line with double tax treaties.
By Anjana Haines
October 16 2018
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Germany: Using statistical analysis to improve TNMM
By Nera

& Philip de Homont

& Yves Hervé
October 15 2018
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US Inbound: Altera decision reversal withdrawn

The Ninth Circuit reversed, and then withdrew its reversal of, the Tax Court's unanimous 'reviewed by the court' decision in Altera Corp. v. Commissioner, 145 T.C. 91 (2015), and held in a 2-1 decision that Treas. Reg...
By David Forst

& Fenwick & West

& Jim Fuller
October 15 2018
This content is from: European Union

Vodafone’s Glenn Price talks tax and risk

Glenn Price, head of international tax at Vodafone, talks to Josh White about the risks taxpayers face in an increasingly uncertain world.
By Josh White
October 15 2018
This content is from: Australia

The Asia Tax Awards 2019: Enter now

Companies, firms and individuals working in jurisdictions across the Asia Pacific region can enter now to compete for the Asia Tax Awards 2019.
By Anjana Haines
October 15 2018
This content is from: United States

New TP cases in MAPs are up by 25% in 2017

The number of transfer pricing cases entering mutual agreement procedures (MAPs) has increased, with France, Germany, India, Italy and the US involved in many of these cases.
By Anjana Haines
October 11 2018
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The reality of Decree 20

Vietnam’s regulatory changes have required an increasing number of taxpayers having to be aware of the transfer pricing rules, explain Hoang Thuy Duong, Tran Thi Thuy Ha and Sandra Liston of KPMG. However, inconsisten...
By ITR Correspondent
October 11 2018
This content is from: Transfer Pricing

Tomas Balco: TP guidance on financial transactions is a challenge

The OECD’s head of the transfer pricing unit tells TP Week why the financial transactions project is the toughest challenge among the four BEPS follow-up work streams he has been focusing on.
By Michael Scaturro
October 09 2018
This content is from: Sponsored

Transparency is trending

Over the past year, the Australian transfer pricing landscape has continued to evolve. There is new legislation and the Australian Taxation Office (ATO) is continuing to prioritise TP as a key area, write Tim Keeling,...
By ITR Correspondent
October 04 2018
This content is from: United Kingdom

Shiv Mahalingham joins Deloitte Middle East

Shiv Mahalingham has left Duff & Phelps in the UK to join Deloitte Middle East as partner and the region’s transfer pricing leader.
By Anjana Haines
October 02 2018
This content is from: Sponsored

Form over substance: The post-BEPS resurgence of the inter-company agreement

Deloitte Australia’s Liam O’Brien looks at how the inter-company agreement is making an important comeback, and how its form can affect its commercial and economic substance.
By ITR Correspondent
October 01 2018

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