This content is from: Canada Bennett Jones adds five to its tax team The Canadian firm Bennett Jones has appointed Ed Kroft, Jehad Haymour, and Deborah Toaze as partners and Sophie Virji and Eric Brown as associates to the Vancouver, Calgary and Toronto offices. November 28 2018
This content is from: Sponsored Deadlines important for taxpayers challenging double taxation under US treaties US taxpayers need to understand how they can obtain double taxation relief via competent authority requests as TP continues to be a top enforcement priority of tax authorities around the world, and one of the major ri... By ITR Correspondent November 28 2018
This content is from: European Union CJEU rules France cannot charge withholding tax on non-resident dividends The Court of Justice of the European Union (CJEU) has said France has discriminated against non-resident loss-making companies when imposing a withholding tax (WHT) on dividends paid by French companies. By Anjana Haines November 27 2018
This content is from: Global World TP 2019 - online now The 2019 edition of the World TP guide is now available online. By Jon Moore November 27 2018
This content is from: Australia BHP restructures to gain Australian tax certainty following settlement Multinational mining company BHP has settled the long-running transfer pricing dispute over its Singapore marketing hub with the Australian Taxation Office (ATO), but has had to change its business model to guarantee ... By Anjana Haines November 22 2018
This content is from: Sponsored How to self-assess your transfer pricing compliance risk in Australia Australia’s transfer pricing legislation is self-executing, placing the onus on taxpayers to self-assess their transfer pricing positions and to be able to demonstrate that there is no “transfer pricing benefit”, writ... By ITR Correspondent November 22 2018
This content is from: United States Taxpayers caught in the crossfire of BEPS and US tax reform US multinational companies are worried by the unilateral approach of some countries on the OECD’s BEPS actions, while others are grappling with the challenges of US tax reform. By Josh White November 19 2018
This content is from: European Union EU court sides with Commission in Santander state aid dispute The EU General Court has ruled that Spain’s 2001 tax scheme for foreign acquisitions constitutes illegal state aid. The case offers clues on the direction of pending decisions on Starbucks, Fiat, Apple and others. By Anjana Haines November 15 2018
This content is from: Switzerland KPMG appoints Jonathan Bernsen to lead Swiss TP team Jonathan Bernsen has joined KPMG Switzerland to head its transfer pricing team. By Anjana Haines November 14 2018
This content is from: Nigeria Five minutes with Nigeria’s Tunde Fowler on transfer pricing Tunde Fowler, executive chairman of the Nigerian Federal Inland Revenue Service (FIRS), talks to TP Week about the 2018 transfer pricing regulations, the challenges of moving away from oil revenues, as well as audits,... By Anjana Haines & Joseph Stanley-Smith November 13 2018
This content is from: Austria Disagreement on EU’s digital tax plans shifts proposed effective date Continuing disagreement among member states over the scope of the EU’s plan to tax the digital economy has forced its biggest advocates to concede into delaying the proposed effective date. By Anjana Haines November 08 2018
This content is from: Sponsored Italian tax agency clarifies transfer pricing adjustments and VAT The Italian Revenue Agency has clarified the VAT treatment of transfer pricing (TP) adjustments via a tax ruling on November 2 2018. Antonella Della Rovere and Federico Vincenti of Crowe Valente / Valente Associati GE... By Antonella Della Rovere & Crowe Valente/Valente Associati GEB Partners & Federico Vincenti November 07 2018
This content is from: Canada Reopening of Cameco case risks four-year tussle over TP disagreements Cameco is certain that it will win its TP dispute with the Canada Revenue Agency (CRA) as the matter heads to the Federal Court of Appeal. The outcome could change how the CRA can apply TP rules. By Anjana Haines November 06 2018
This content is from: Sponsored China: More tax measures to cope with the challenging global economic environment In recent months, the trade issues between China and the US have continued to escalate. So far, the US has imposed 10% tariffs on $250 billion out of the more than $500 billion of China exports to the US, and China ha... By Khoonming Ho & KPMG China & Lewis Lu November 05 2018
This content is from: Sponsored Hong Kong: Chief executive’s 2018 policy address sets out tax plan Chief Executive Carrie Lam Cheng Yuet-ngor delivered her second policy address on October 10 2018, which sets out the Hong Kong government’s policies over the coming years. By Curtis Ng & KPMG China & Lewis Lu November 01 2018
This content is from: Canada CRA may use its GAAR to guide PPT advance rulings and assessments The Canada Revenue Agency has suggested that its general anti-avoidance rule and related case law could shed some light on how the principal purpose test may be applied to transactions. But advance rulings are advised. By Anjana Haines November 01 2018
