This content is from: Global 2020: The best of transfer pricing A quick look back at some of ITR’s best articles on transfer pricing from the Apple state aid case and a slew of other high stakes tax disputes to the OECD’s work on the digital economy. By Josh White December 24 2020
This content is from: Direct Tax This week in tax: OECD makes digital tax feedback public As the end of 2020 approaches, multinational companies like Amazon, Microsoft and Uber have told the OECD what they think of the blueprints for digital tax reform in a public consultation. By Josh White December 18 2020
This content is from: Sponsored OECD FT Report: A potential solution to excessive debt financing Costas Savva and Demis Ioannou of Taxatelier take a closer look at protective tax measures for excessive debt financing, and consider whether the new FT Report can be a solution for existing problems. By Costas Savva & Demis Ioannou & Taxand Cyprus December 18 2020
This content is from: Transfer Pricing Uber recommends the OECD rethink Amount A scope Ride-sharing company Uber has reiterated its doubts over the OECD’s pillar one blueprint and taken issue with the scope of Amount A. The company recommends refining and narrowing the scope to fit the OECD’s goals. By Josh White December 17 2020
This content is from: Transfer Pricing UK MNEs should share TP arrangements with HMRC, say advisors Multinational enterprises (MNEs) should engage with HM Revenue and Customs (HMRC) and its Profit Diversion Compliance Facility to prevent the need for investigations. By Alice Jones December 16 2020
This content is from: Sponsored Romania: Considerations on country-by-country reporting requirements Adrian Rus and Gabriela Bancescu of EY Romania take a closer look at the transfer pricing compliance and reporting obligations for businesses operating in Romania. By Adrian Rus & EY Romania & Gabriela Bancescu December 15 2020
This content is from: Transfer Pricing COVID-19 to increase TP scrutiny on MNE inter-company loans Tax professionals told ITR that they expect the COVID-19 pandemic to intensify scrutiny on multinational enterprises’ (MNEs) transfer pricing (TP) arrangements. By Alice Jones December 11 2020
This content is from: Sponsored New rules for Italian TP documentation: Groups may need to revise approach Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners assess the changes for businesses to consider, as Italy’s transfer pricing documentation guidance evolves to better reflect the OECD’s guidelines. By Barbara Scampuddu & Gian Luca Nieddu & Hager & Partners December 11 2020
This content is from: United States US taxpayers reassess APAs over the COVID-19 crisis US companies are taking COVID-19 into account for existing advance pricing agreements (APAs) and particularly for new agreements they are trying to secure with the Internal Revenue Service (IRS). By Josh White December 10 2020
This content is from: United States Businesses learn TP governance lessons from CbCR Companies have learned important lessons on how to organise their transfer pricing (TP) functions since country-by-country reporting (CbCR) came into force, putting them in a better position to face-off audits. By Josh White December 10 2020
This content is from: Direct Tax Rising Stars Awards Europe 2020: shortlist revealed Up and coming tax practitioners from Allen & Overy, Jones Day, Deloitte, Uría Menéndez, Garrigues, and many more have been shortlisted for the Rising Stars Awards Europe 2020. By ITR Correspondent December 10 2020
This content is from: Direct Tax Women in Business Law Awards Asia-Pacific 2020 – Winners announced By ITR Correspondent December 10 2020
This content is from: OECD OECD advances its tax certainty agenda ahead of digital tax reform Achim Pross, head of the international cooperation and tax administration division at the OECD, says the Forum on Tax Administration’s (FTA) December 8 plenary session may help advance discussions on dispute preventio... By Danish Mehboob December 07 2020
This content is from: Sponsored Thailand: A closer look at the updates to CbCR Andrew Jackomos and Rohit Sharma of HLB Thailand assess how country-by-country reporting (CbCR) regulations are evolving in Thailand, and consider the implications for businesses. By Andrew Jackomos & HLB Thailand & Rohit Sharma December 03 2020
This content is from: Belgium Advocate General: CJEU should set aside the Belgian state aid ruling Advocate General Juliane Kokott has advised the CJEU to set aside the General Court’s judgment that the Belgian excess profit tax regime does not constitute illegal state aid. By Josh White December 03 2020
This content is from: United States How businesses are restructuring to bring TP documentation in-house Multinational companies (MNEs) are moving more of the transfer pricing (TP) documentation work in-house, but each business has a different approach. By Josh White December 03 2020
This content is from: Global MNEs oppose mandatory public CbCR over data inconsistencies Tax directors at multinational enterprises (MNEs) have warned that low data quality and inconsistency in reporting requirements across jurisdictions means public country-by-country reporting (CbCR) should not be made ... By Alice Jones December 02 2020
This content is from: Sponsored Italy publishes updated 2020 transfer pricing documentation guidance Federico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners outline the key elements for businesses to consider from the provision which amended the 2010 transfer pricing documentation require... By Carola Valente & Crowe Valente/Valente Associati GEB Partners & Federico Vincenti December 02 2020
