This content is from: United States IRS gears up for TP in 2019 After losing a slew of major disputes, the US Internal Revenue Service (IRS) is ramping up its efforts for transfer pricing (TP) cases in 2019. By Josh White December 21 2018
This content is from: United States The rise of a new transfer pricing order Even after the EU’s digital tax plan hit a major roadblock, transfer pricing (TP) directors feel the global order shifting away from the arm’s-length principle (ALP) and towards formulary apportionment. By Josh White December 18 2018
This content is from: Qatar Saudi businesses prepare the ground for new TP rules Saudi Arabia has released its new transfer pricing standards in an effort to align with OECD standards from January 2019, but even the status quo brings some anxiety for taxpayers. By Josh White December 13 2018
This content is from: Sponsored Mexican 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 December 12 2018
This content is from: Sponsored Germany: Profit-split considerations in TNMM solutions in a post-BEPS world The combined effect of the globalisation of entrepreneurial responsibilities within multinationals and the OECD's BEPS initiative puts traditional one-sided transfer pricing (TP) methods under increased pressure. NERA... By Nera & Philip de Homont & Yves Hervé December 12 2018
This content is from: Sponsored Beware of Canadian withholding tax and the breadth of the restrictive covenant rules Under Canadian rules, receipt of a payment for a 'restrictive covenant' is generally included in income or subject to Canadian withholding tax when made to a non-resident. By ITR Correspondent December 12 2018
This content is from: Sponsored Ireland: ATAD implementation continues with the introduction of CFC rules and exit charge By Brian Doohan & Matheson & Trevor Glavey December 12 2018
This content is from: Sponsored ATO releases draft guidance on offshore shipping service hubs The Australian Taxation Office (ATO) has released a draft schedule that deals with offshore shipping service hubs. By ITR Correspondent December 11 2018
This content is from: Sponsored A Sisyphean task? – Tax plays catch up with China’s rapid digitalisation The increasing size and sophistication of China’s digital economy, as well as the rapid expansion of Chinese digital economy enterprises into foreign markets, is highlighting a range of complex tax issues, and the imp... By Conrad Turley & Khoonming Ho & KPMG China & Mimi Wang & Sunny Leung December 10 2018
This content is from: Sponsored Not-so-old wine, in a not-so-new bottle – perennial tax challenges for M&A John Gu, Chris Mak and Fiona He explore the key tax issues and considerations of China inbound M&A deals, especially in the education and real estate sectors, including practical challenges for cross-border transactio... By Christopher Mak & KPMG China December 10 2018
This content is from: Sponsored Tax opportunities and challenges for China in the BRI era Chinese governmental authorities remain supportive of rational, well-ordered and healthy outbound investment. Michael Wong, Joseph Tam, Karen Lin, Cloris Li and Alan O’Connor look at key domestic tax and regulatory me... By Alan O'Connor & Cloris Li & Joseph Tam & Karen Lin & KPMG China & Michael Wong December 10 2018
This content is from: Sponsored Tax means business – Hong Kong’s tax policies to increase competitiveness Hong Kong has seen substantial changes to its tax landscape in 2018. Curtis Ng, Michael Olesnicky, John Timpany and Ivor Morris discuss Hong Kong’s tax changes for transfer pricing (TP) and research and development (R... By Curtis Ng & KPMG China December 10 2018
This content is from: India Akhilesh Ranjan on India’s TP priorities Akhilesh Ranjan, India’s principal chief commissioner of income tax (international), gives his perspective on how transfer pricing should be reformed and India’s next step to protect its tax base. By Anjana Haines December 07 2018
This content is from: United States TP arrangements resilient to shock of US tax reform The Tax Cuts and Jobs Act (TCJA) has changed a lot about US tax law, yet TP directors may have more certainty about the future than their counterparts in corporate tax. By Josh White December 06 2018
This content is from: Global No. 8: Pascal Saint-Amans and Achim Pross This year has been a momentous when considering what the OECD's Centre for Tax Policy and Administration has achieved. Many aspects of the BEPS project have come to fruition even though nobody thought it was possible ... By Anjana Haines December 05 2018
This content is from: Sponsored EU DAC6 mandatory disclosure rules – why should Swiss intermediaries care? Swiss entities must carefully consider the impact of DAC6 now, which requires the disclosure of certain cross-border tax planning arrangements to local tax authorities. By ITR Correspondent December 04 2018
This content is from: Sponsored Indian tax treaty benefits available without providing a tax residency certificate A recent court ruling means non-resident taxpayers could now claim relief under a tax treaty without obtaining a tax residency certificate (TRC) from their country of residence. By ITR Correspondent December 04 2018
