This content is from: Transfer Pricing ITR Digital Economy Summit 2020 spotlights OECD digital tax plans The OECD’s digital tax plans were the highlight of this year’s ITR Digital Economy Summit as the online marketplace expands amid the COVID-19 pandemic and taxpayers speculate on multiple taxation risks ahead of a glob... By Danish Mehboob October 30 2020
This content is from: Sponsored Recognising intra-group loans following the OECD’s FTTP guidance Christos Theophilou and Costas Savva of Taxatelier consider how the OECD’s guidance on financial transactions and transfer pricing (FTTP) can be interpreted in consideration of intra-group loans. By Christos Theophilou & Costas Savva & Taxatelier October 30 2020
This content is from: Sponsored US: Thinking through secondary transfer pricing adjustments Mark Martin and Thomas Bettge of KPMG in the US explore the nature and tax consequences of secondary adjustments arising from transfer pricing adjustments initiated by tax authorities or taxpayers. By KPMG US & Mark Martin & Thomas Bettge October 29 2020
This content is from: Global Register now: Research process for World Tax/TP and ITR Awards 2021 to be aligned Companies, firms and individuals can now register to be alerted for the beginning of the research for 2021’s global tax awards programme. By Jon Moore & Prin Shasiharan October 29 2020
This content is from: Sponsored Assessing the transfer pricing treatment of COVID-19 restructuring Niraja Srinivasan, Yves Hervé and Philip de Homont of NERA Economic Consulting take a closer look at the transfer pricing challenges and solutions that have emerged from restructuring expenses during the coronavirus p... By Nera & Niraja Srinivasan & Philip de Homont & Yves Hervé October 29 2020
This content is from: Transfer Pricing Banks reconsider inter-company loan calendars over COVID-19 Banks are having to consider different approaches to past inter-company (IC) loans to secure repayments, while the pricing of new loans remains stable for the time being. By Josh White October 28 2020
This content is from: European Union Research suggests Europe’s largest banks continue to avoid tax Research by anti-corruption watchdog Transparency International EU (TI EU), carried out using country-by-country reporting (CbCR) data, suggests widespread use of profit shifting and tax havens among 39 of the largest... By Alice Jones October 27 2020
This content is from: Transfer Pricing The OECD’s FTTP guidance may make tax authorities more aggressive The OECD’s guidance on financial transactions and transfer pricing (FTTP) may offer tax authorities extra tools in their pursuit of offshore financing structures in high stakes audits. By Josh White October 22 2020
This content is from: Transfer Pricing EU state aid cases fail to clarify the arm’s-length principle for MNEs Many companies are still grappling with uncertainty over transfer pricing (TP) rules because of the disparity in how EU rules are applied in member states, specifically on how to apply the arm’s-length principle (ALP)... By Josh White October 22 2020
This content is from: Direct Tax OECD’s blueprint on global minimum tax is a ‘compliance monster’ The OECD expects to reach an agreement on its two-pillar digital tax blueprints by mid-2021, but many stakeholders still say the approach is too complicated, while alternative tax proposals risk trade wars and multipl... By Danish Mehboob October 16 2020
This content is from: European Union Autumn tax disputes: EU state aid law still causing headaches Businesses are still facing uncertainty over their tax arrangements due to ongoing disputes over everything from state aid to intangible assets at the EU-level and the national level. By Josh White October 15 2020
This content is from: Sponsored Beyond the pandemic: Global transfer pricing trends drive change It is no secret that the world is changing at an accelerated rate. The world of transfer pricing is no exception, explains Oleg Rak of Mason Rak. The practice – like everything else in these unprecedented times – will... By Mason Rak & Oleg Rak October 08 2020
This content is from: Global Pillar one could force MNEs to outsource more tax work The OECD’s plans to rewrite profit allocation rules could force some businesses to seek the assistance of external advisors to manage the administrative demands created by the “monster” that is pillar one. By Josh White October 08 2020
This content is from: Global Why Syngenta’s tax team was well-placed for COVID-19 Avni Dika, global head of transfer pricing at Syngenta, talks to ITR about how remote working and a shared service centre has helped the tax function to operate more effectively during the coronavirus pandemic. By Josh White October 07 2020
This content is from: India Vodafone’s victory in India spells certainty for taxpayers UK telecommunications group Vodafone has won its long battle with the Indian Income Tax Department after more than a decade in the courts. By Josh White October 02 2020
This content is from: Transfer Pricing Most TP structures have survived the COVID-19 crisis Most companies have managed to keep their transfer pricing (TP) structure and value chains the same despite the impact of the COVID-19 pandemic, according to polls conducted at ITR’s Global Transfer Pricing Forum. By Josh White October 01 2020
