This content is from: European Union The OECD searches for new profit allocation rules The OECD’s search for a solution to profit allocation continues, after the G7 committed to a global minimum tax rate, however, any change will be deeply contested. By Josh White August 29 2019
This content is from: Transfer Pricing PPT: Business purpose as a tax professional As the Multilateral Instrument’s (MLI) provision for the principal purpose test (PPT) is nearing effect, the business-purpose standard becomes even more important to objectively ascertain. Keith Brockman explains the ... By Keith Brockman August 29 2019
This content is from: Sponsored Germany: Approaching VCA and DEMPE analysis Yves Hervé and Philip de Homont from NERA Economic Consulting propose a practical approach to structuring DEMPE analysis. By Nera & Philip de Homont & Yves Hervé August 29 2019
This content is from: Transfer Pricing What is ‘mere selling’ and why should we care? It may seem like an odd question for an international tax journal to ask, but the OECD’s report on its programme of work on digital tax indicates that we may be at the end of whatever certainty we thought we had about... By Contributor August 29 2019
This content is from: Sponsored US outbound: IRS CAP programme reopens with attention to transfer pricing Mark Horowitz, Thomas Bettge, Mark Martin, and Theresa Kolish of KPMG assess the IRS’s reopening of the CAP programme, noting that the updated programme seeks to address transfer pricing issues. By KPMG US & Mark Martin & Thomas Bettge August 29 2019
This content is from: Sponsored EU: Full tax harmonisation under the new Von der Leyen Commission? Bob van der Made of PwC assesses the current level of tax harmonisation across EU member states, and evaluates whether there would be further harmonisation under a new EU Commission. By Bob van der Made & PwC August 29 2019
This content is from: Transfer Pricing Managing BEPS and tax audits is a balancing act for heads of tax Since its introduction in 2016, the OECD’s project to combat base erosion and profit shifting (BEPS) has changed the environment for tax audits around the world. Corporations and heads of tax have to adapt, says Sandy... By Sandy Markwick August 29 2019
This content is from: Sponsored Italy: Italian Supreme Court rules on place of effective management Gian Luca Nieddu and Barbara Scampuddu of Hager Partners analyse a Supreme Court ruling which declared a company was resident in the Netherlands because its effective management took place in this jurisdiction. By Barbara Scampuddu & Gian Luca Nieddu & Hager & Partners August 29 2019
This content is from: Global TP and credit ratings: The impact of passive association The lack of guidance on the impact of passive association on a stand-alone credit profile (SACP) leads to uncertainty in transfer pricing (TP) analyses for multinational corporations. By TP Week Contributor August 29 2019
This content is from: United States Uber makes the case for a residual profit split Uber has proposed a modified residual profit split (MRPS) as a solution to the problems of taxing the high-tech industry. This proposal may be a game-changer in the digital tax debate. By Josh White August 27 2019
This content is from: Transfer Pricing Big tech changed everything for international tax The OECD has been forced to question its own assumptions since the high-tech sector destabilised the international tax system. Taxpayers fear this shift will herald radical change, writes Josh White. By Josh White August 22 2019
This content is from: United States Apple set for showdown with the EU over state aid The EU’s General Court is due to hear the state aid case over Apple’s multibillion-euro tax bill in Ireland following several years of intense court battles, but this couldn’t come at a worse time. By Josh White August 22 2019
This content is from: Global TP and credit ratings: Establishing the stand-alone credit profile A multinational’s transfer pricing documents are a valuable source of information when trying to understand the functional profile of an entity and determine the stand-alone credit profile. By TP Week Contributor August 21 2019
This content is from: United States Amazon beats the IRS in US intangibles case Amazon defeated the US Internal Revenue Service (IRS) in an appeal case over assets moved to Luxembourg more than a decade ago. However, other companies may not be so fortunate to win. By Josh White August 20 2019
This content is from: United States How NGOs changed the global tax debate After winning battles over financial transparency, the Tax Justice Network (TJN) is helping to make radical proposals mainstream. First it was country-by-country reporting, now it may be formulary apportionment. By Josh White August 14 2019
This content is from: Global TP and credit ratings: Determining the anchor rate Although commercial tools are widely used by transfer pricing (TP) practitioners and tax authorities to determine the risks posed by borrowers with no previous credit ratings, there are some grey areas on how to apply... By TP Week Contributor August 14 2019
This content is from: Transfer Pricing How NGOs changed the global tax debate After winning battles over financial transparency, the Tax Justice Network (TJN) is helping to make radical proposals mainstream. First it was country-by-country reporting, now it may be formulary apportionment. By Josh White August 14 2019
This content is from: United Kingdom IFA President: The arm’s-length principle will survive BEPS 2.0 Despite the storm of the digital tax debate, the world will find it hard to do without the arm’s-length principle (ALP). TP Week speaks to IFA President Murray Clayson about the future of the ALP. By Josh White August 13 2019
This content is from: United Kingdom What to expect at the IFA 2019 Congress International Tax Review speaks to IFA President Murray Clayson about the prospects for “radical change” on digital tax and why the London Congress will focus on BEPS Action 4 and the challenges facing investment funds. By Josh White August 09 2019
This content is from: European Union Big tech changed everything for international tax The OECD has been forced to question its own assumptions since the high-tech sector destabilised the international tax system. Taxpayers fear this shift will herald radical change. By Josh White August 06 2019
This content is from: European Union EU looks at using R&D costs to solve digital tax impasse The European Commission is set to look at the possibility of using R&D costs as a way of reallocating income. This may be the starting point for an EU-wide solution to taxing the digital economy. By Josh White August 01 2019
