Transfer Pricing

Archive: Transfer Pricing

This content is from: Japan

Japanese companies fear the rise of the profit split method

As Japan moves towards a new transfer pricing (TP) regime, companies fear the increasing use of the profit split method could erode the arm’s-length principle (ALP).
By Josh White
January 31 2019
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Now that China has data, what is it going do with it?

China has introduced a profit monitoring mechanism that taps into big data analysis to carry out risk assessments so that more targeted administrative action can be taken against large taxpayers.
By ITR Correspondent
January 29 2019
This content is from: Georgia

Country ceiling principle offers TP alternative for developing countries

The lack of comparables remains one of the biggest challenges for transfer pricing (TP) professionals, especially in low capacity countries. Gela Barshovi explains how the country ceiling principle may help companies ...
By ITR Correspondent
January 29 2019
This content is from: Sponsored

India: Delhi’s High Court maintains that overseas GE entities have a PE in India

Delhi High Court (HC) has confirmed the Income Tax Appellate Tribunal's decision that various overseas entities of the GE Group had a fixed place, permanent establishment (PE), and a dependent agent PE in India.
By Dhruva Advisors

& Rakesh Dharawat

& Rishi Kapadia
January 28 2019
This content is from: Sponsored

ATO releases guidelines for inbound distributors, hybrid mismatch rules

In recent months, there have been several important tax developments driven by the Australian Taxation Office (ATO) that are relevant to inbound distributors, multinationals and foreign-incorporated companies.
By DLA Piper Australia

& Jun Au
January 28 2019
This content is from: Sponsored

Canada confirms withholding tax can apply to the assumption of accrued interest

Canada's Revenue Agency (CRA) confirmed in a recent technical interpretation (2017-071330117) that Canadian withholding tax can apply to the accrued (but unpaid) interest on a debt owed by a Canadian resident to a non...
By ITR Correspondent
January 28 2019
This content is from: Sponsored

Germany: Digitisation trends and use of the profit split method
By Nera

& Philip de Homont

& Yves Hervé
January 28 2019
This content is from: Sponsored

Israel’s tax outlook for 2019 eyes exponential R&D investment

With spending on research and development (R&D) and venture capital investment as a percentage of GDP among the highest in the world, Israel has entered 2019 as a leading technology country.
By Henriette Fuchs

& Pearl Cohen Zedek Latzer Baratz
January 28 2019
This content is from: United Kingdom

TP data automation holds the key to CbCR success

Country-by-country reporting (CbCR) has intensified the focus on data quality among companies and is a key factor in the drive towards automating some transfer pricing compliance.
By Josh White
January 24 2019
This content is from: United States

China and the US could define the digital tax debate

The first signs of unity on digital tax might come from an unlikely partnership in 2019 as the pressure grows on the OECD to find a consensus.
By Josh White
January 17 2019
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. Curtis Ng, Michael Olesnicky, John Timpany and Ivor Morris discuss the tax changes for TP and R&D aimed at enhancing competitiveness and economic growth.
By ITR Correspondent
January 16 2019
This content is from: European Union

EU probes Nike’s web of TP arrangements for illegal state aid

Nike and its subsidiary brand Converse have joined the parade of US multinationals being investigated by the EU over transfer pricing arrangements that have allegedly allowed them to gain an unfair competitive advantage.
By Anjana Haines
January 15 2019
This content is from: United Kingdom

The UK launches DPT disclosure facility

As part of its crackdown on tax avoidance, HM Revenue & Customs has introduced the profit diversion compliance facility (PDCF), forcing UK taxpayers to choose between voluntary disclosure or be investigated over their...
By Josh White
January 11 2019
This content is from: New Zealand

KPMG grows tax disputes and TP teams with new hires

KPMG has appointed Angela Savin as partner in its disputes and investigations team, and Kriti Velji and Nick Stevart both join as directors in the transfer pricing team.
By Anjana Haines
January 09 2019
This content is from: United States

Japan's TP proposals to hit IP assets

Japan’s proposals to reform its transfer pricing (TP) rules are likely to hit Japanese companies with domestic IP assets much harder than foreign multinationals operating in the country, warn tax directors.
By Alexander Hartley

& Josh White
January 09 2019
This content is from: Transfer Pricing

A practical guide for operational transfer pricing excellence

A well-constructed and executed global operational transfer pricing (OTP) framework is essential to properly manage financial statements, taxes and reputational risk for multinational enterprises (MNEs).
By ITR Correspondent
January 08 2019
This content is from: United States

Companies redouble TP efforts over dispute fears

Facing more scrutiny than ever, multinational companies are devoting a growing amount of resources to transfer pricing (TP) policy in a bid to avoid damaging court cases.
By Josh White
January 03 2019

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