Transfer Pricing

Archive: Transfer Pricing

$OECD to consider worldwide fractional apportionment$
This content is from: United States

OECD to consider worldwide fractional apportionment

The OECD’s Inclusive Framework countries have agreed to a 40-page report that outlines potential ways to tax the digital economy. The document suggests, among other measures, introducing worldwide fractional apportion...
By Alexander Hartley
May 31 2019
This content is from: Australia

Training interviewees in TP audits more important than ever

Tax authority auditors are fishing for information they can use in tax and transfer pricing audits by interviewing company staff and customers. The tax function must ensure staff who are interviewed are prepared.
By Anjana Haines
May 30 2019
This content is from: Sponsored

The impact of TP policies on managing a company in crisis

Companies need to take extra care when choosing their transfer pricing methodology and determining how to apply it, warn tax advisors from Valente Associati GEB Partners/Crowe Valente.
By Carola Valente

& Crowe Valente/Valente Associati GEB Partners

& Sara Parillo
May 30 2019
This content is from: United States

Survey results: Effective IP management

Multinational companies told TP Week how they dealt with the challenge of restructuring their intellectual property in a world of tax disputes, greater transparency and new rules.
By Josh White
May 29 2019
This content is from: Sponsored

Hong Kong SAR's economic substance requirements for offshore jurisdictions

A number of offshore jurisdictions such as the Cayman Islands, the British Virgin Islands (BVI) and Bermuda have introduced economic substance laws.
By Curtis Ng

& KPMG Hong Kong

& Lewis Lu
May 28 2019
This content is from: Sponsored

New Zealand rejects capital gains tax

New Zealand's government has rejected the recommendation of its tax working group (TWG) that New Zealand introduce a capital gains tax (CGT). Announcing the government's decision, Prime Minister Jacinda Ardern acknowl...
By Brendan Brown

& Matt Woolley

& Russell McVeagh
May 28 2019
This content is from: Argentina

Argentina updates its global tax treaties with key economies

In early December 2018, Argentina signed two new double tax treaties (DTTs) with China and Turkey. In January 2019, Congress passed Law No. 27,496, which approved the DTT signed between Argentina and the United Arab E...
By Ignacio Rodríguez

& PwC Argentina
May 28 2019
This content is from: Sponsored

Luxembourg: Luxembourg’s tax authority seeks verification of permanent establishments

On February 22 2019, Luxembourg's tax authority issued an administrative circular to clarify new rules surrounding permanent establishments. The Luxembourg law includes measures that amend the domestic definition of a...
By Christophe De Sutter

& Deloitte Luxembourg
May 28 2019
This content is from: Transfer Pricing

Intangibles: Re-engineering substance

The BEPS project has had a fundamental impact on how multinational companies are structuring their intangible assets. Josh White investigates how businesses are reorganising their tax arrangements to meet their commer...
By Josh White
May 28 2019
This content is from: Sponsored

Israel seeks introduction of a digital sales tax

Israel's Finance Ministry and tax authority announced in the last week of April that they intend to introduce a digital sales tax (DST) that may reap some $280 million for the treasury. The tax authorities will be wor...
By Henriette Fuchs

& Pearl Cohen Zedek Latzer Baratz
May 28 2019
This content is from: Sponsored

Germany: A practical solution for hard to value intangibles

It is likely that many tax disputes will arise from the new definition of hard to value intangibles (HTVI) in the OECD's transfer pricing (TP) guidelines.
By Nera

& Philip de Homont

& Yves Hervé
May 28 2019
This content is from: Direct Tax

Let’s get digital

While some of the answers on how to tax the digital economy are not going to be what everyone likes, we have to admit they make for good conversation. The OECD has to handle things just right. For India, though, there...
By Joe Stanley-Smith
May 28 2019
This content is from: Direct Tax

The OECD’s consultation on addressing the tax challenges of the digital economy

The OECD released its ideas for reforming the international tax system. Companies responded and International Tax Review reported.
By Alexander Hartley
May 28 2019
This content is from: United States

Growing number of businesses onshoring IP since BEPS

Around 90% of companies surveyed by TP Week said BEPS has impacted their operations more than the EU Anti-Tax Avoidance Directive and US tax reform combined, while many are analysing the benefits of onshoring intangib...
By Josh White
May 28 2019
This content is from: United States

Vestager makes bid to decide the future of EU tax policy

European Competition Commissioner Margrethe Vestager could become the next president of the European Commission (EC) as voting commences, but state aid remains on her agenda no matter what the result.
By Josh White
May 23 2019
$India’s fractional apportionment proposals are an ‘invitation to chaos’$
This content is from: India

India’s fractional apportionment proposals are an ‘invitation to chaos’

Taxpayers are concerned that India’s proposal to introduce a fractional apportionment model could lead to double taxation and a subsequently higher number of mutual agreement procedure cases.
By Josh White
May 22 2019
This content is from: Sponsored

Does India’s proposals on attribution of profits to PEs solve the issue?

Suchint Majmudar and Mudigonda Vishweshwar of Deloitte India discuss India’s proposed amendments on the attribution of profits to permanent establishments (PEs) of non-resident enterprises, and provide their observati...
By ITR Correspondent
May 20 2019
This content is from: United States

US companies seek inversions despite GILTI rules

The US Tax Cuts and Jobs Act (TCJA) appears to have inadvertently created new incentives that allow companies to continue shifting profits and assets out of the US.
By Josh White
May 16 2019
This content is from: Austria

Survey: Taxation of the digital economy

The global community plans to reshape the international tax rules to address the tax challenges of the digitalising economy. Companies must react.
By Alexander Hartley
May 16 2019
$Taxpayers say India’s proposed move to fractional apportionment would intensify disputes$
This content is from: India

Taxpayers say India’s proposed move to fractional apportionment would intensify disputes

The consultation period for feedback on India’s proposed changes to its profit-attribution rules has not yet ended, but the debate around the potential costs and benefits of any change is already hotting up.
By Alexander Hartley

& Joseph Stanley-Smith
May 15 2019
This content is from: Australia

‘Smart manufacturing’ blurs the definitions of PE, goods and services

Taxpayers at this year’s Asia Tax Forum said the popularity of manufacturing ‘smart’ products is adding to the confusion of whether, and at what point, certain goods should be defined as services and where they should...
By Anjana Haines
May 14 2019
This content is from: United States

Businesses face dual challenge in low-tax jurisdictions

Multinational companies based in low-tax jurisdictions are facing the prospect of more transparency and higher substance requirements than ever before.
By Josh White
May 09 2019
This content is from: European Union

Houthoff hires new TP counsel from VEON

Dutch firm Houthoff has hired TP specialist Rezan Ökten as counsel as part of its tax practice. Ökten joins the practice after several years working in-house at VEON and Liberty Global.
By Josh White
May 09 2019
This content is from: United States

Microsoft's audit woes mirrored worldwide

Microsoft may be worth $1 trillion, but it still has plenty of unfinished business with the IRS and there is no sign of a final resolution this year. It is far from the only company suffering from lengthy audit proced...
By Josh White
May 07 2019
This content is from: Sponsored

Canada’s 2019 federal budget introduces transfer pricing measures

Deloitte’s Phil Fortier and Tony Anderson summarise the transfer pricing (TP) measures in Canada’s 2019 federal budget.
By ITR Correspondent
May 02 2019
This content is from: Sponsored

IRS clarifies mandatory consultation process regarding transfer pricing examinations

The US IRS has revised its internal manual on TP examinations. Deloitte explores the memorandum’s impact on collaboration between large businesses and international taxpayers and the advance pricing and mutual agreeme...
By ITR Correspondent
May 01 2019
This content is from: Sponsored

Australia issues taxpayer alert on payment mischaracterisation regarding intangible assets

The ATO has issued a taxpayer alert on what it considers to be a high-risk mischaracterisation of payments for intangible assets. Deloitte Australia’s John Bland and Milla Ivanova explain the consequences.
By ITR Correspondent
May 01 2019
This content is from: Sponsored

Italy clarifies key transfer pricing tenants

Italy’s tax authority clarified a number of transfer pricing regulations at the nation’s annual tax conference, Telefisco. Salvatore Mattia and Federico Vincenti from Crowe Valente explore the key changes surrounding ...
By Crowe Valente/Valente Associati GEB Partners

& Federico Vincenti

& Salvatore Mattia
May 01 2019
This content is from: United States

Taxpayers play the waiting game on CbCR audits

Corporate taxpayers expect country-by-country reporting (CbCR) to lead to a number of audits and subsequent disputes, but the tax authorities are yet to make a move and taxpayers are cautious of the silence.
By Josh White
May 01 2019

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