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Which member of the BRICS has the most developed TP regime?

South Africa

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Ireland divided over €13 billion Apple tax appeal

Ireland’s government has a dilemma: should it collect €13 billion ($14.5 billion) in back taxes from Apple or spend years fighting to return the money and trying to prove Dublin's tax dealings were legal? August 31, 2016

EC ruling: Ireland gave Apple billions in illegal tax breaks

European investigators said Ireland offered selective treatment allowing Apple to pay 1% or less in tax on European profits in a decision certain to ratchet up trans-Atlantic tension. August 30, 2016

US pressures EU on State Aid before Apple, Amazon rulings

The US has put pressure on Europe ahead of State Aid rulings on Apple and Amazon that could cost American companies – and potentially US tax authorities – billions of dollars in back taxes. August 25, 2016

OECD asks for help targeting branch mismatch structures

The OECD has drafted recommendations to help countries target tax avoidance by multinationals using branch mismatch structures. August 24, 2016

Turkey narrows ‘related party’ definition in TP legal overhaul

Turkey has significantly altered its transfer pricing regulations, including narrowing the definition of ‘related party’ which could help its investment climate. August 22, 2016

News Briefs for August 22

The biggest transfer pricing news including updates on Liechtenstein's plans to exchange tax information; IRS country-by-country reporting guidance and the Finnish tax authority's invitation to MNEs with TP questions. August 22, 2016

US elections: Presidential plans for corporate inversions

Donald Trump says he will curb 'job-killing corporate inversions' by reducing the US business tax rate from 35% to 15%. Hillary Clinton plans to levy an "exit tax" on businesses moving overseas. Will either tax plan work? August 18, 2016

Apple CEO: 'We’re not a tax dodger'

As the EU prepare to rule on whether Apple’s Irish tax arrangements constitute billions of dollars in illegal State aid, Tim Cook sat down with the Washington Post to mark his five years as CEO and discuss the multinational’s tax record. August 15, 2016

Facebook ordered into court over Dublin IP transfer

Facebook must explain to a California judge why the company should not have to comply with IRS demands for information about an intellectual property transfer to Ireland. The dispute could cost Facebook as much as $5 billion. August 12, 2016

Brexit aftershocks: Are multinationals ready?

Multinationals are considering how Brexit negotiations will affect tax and transfer pricing arrangements, but how are they preparing? TP Week's sister publication ITR and KPMG are surveying companies as the European Union exit looms. August 10, 2016

How Medtronic won against the IRS

Medtronic is a recent and important US transfer pricing case. The case involved, among other things, the royalty rate payable by a Puerto Rican affiliate of the US taxpayer that produced medical device products. August 09, 2016

NEWS BRIEFS for August 4

The biggest transfer pricing news including UK drives for transparency, rejection of Belgium state aid appeal and draft CbCR legislation for Canada. August 04, 2016

Americas Tax Awards 2016: Shortlist announced

The nominees for the 11th annual Americas Tax and Transfer Pricing Awards are announced today. August 01, 2016

Facebook potentially facing $5 billion tax bill

A US Internal Revenue Service (IRS) investigation into Facebook could land the technology company with a bill that would have “material adverse impact” on the company’s finances. July 29, 2016

Clarification on Greek TP documentation

Greece has issued two decisions to clarify the application of documentation rules in cases of tax adjustments and the issue of whether Real Estate Investment Companies are liable companies for transfer pricing purposes. July 28, 2016

The transfer pricing implications of Brexit

The UK’s decision to leave the European Union could have two significant impacts on the transfer pricing environment in the UK: freedom from the relevant EU Directives, and movement of companies or financial and other assets, either into or out of the UK. July 27, 2016

Why investors are pushing for transparent tax planning

The transparency of multinationals’ tax practices is a growing concern for investors because reputational damage from transfer mispricing can negatively affect share prices. November 26, 2015

OECD statistics show MAP remains necessary but slow

The OECD has released statistics on MAP cases for its member states and related economies for 2014. December 01, 2015

Northern Ireland tax rate introduces TP challenge

Northern Ireland will reduce its corporate tax rate to 12.5% in 2018, bringing it in line with the Republic of Ireland tax rate but below the rest of the UK. December 03, 2015

Johann Muller: How a European CCCTB makes BEPS action points “irrelevant”

Johann Muller was the deputy head of tax for a major multinational and, following that, the chief consultant at the Danish competent authority. From both perspectives he sees the benefits and need for a common consolidated corporate tax base (CCCTB) in Europe. December 10, 2015

Singapore updates its transfer pricing guidelines

The Singapore revised transfer pricing (TP) guidelines, published January 6 2015, require taxpayers to prepare and maintain contemporaneous TP documentation to support TP positions and have this in place by the time the company’s tax return is filed. January 19, 2015

New TP reforms in Ukraine likely to ramp up disputes and prolong audits

The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pricing control. January 14, 2015

China focuses on cross-border transactions in war on tax evasion

The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. The move signals a crackdown on profit shifting, which could see cross-border transactions increasingly scrutinised. January 12, 2015

Lack of transfer pricing rules leads to questionable audits in Hong Kong

Despite a self-touted reputation as a leading global financial centre, Hong Kong’s Inland Revenue Department (IRD) has been criticised by tax practitioners for overly aggressive audits on asset managers. Hong Kong has limited transfer pricing legislation and often seeks to enforce arm’s-length pricing through practice notes and a network of tax treaties. January 08, 2015

The transfer pricing implications of the Italian regional tax on productive activities

The provincial tax court of Reggio Emilia has issued ruling No 510/03/14 relating to the Italian regional tax on productive activities (IRAP). January 06, 2015

Reduction in maximum income tax rate for inclusion in Brazil’s black and grey lists

The Brazilian Ministry of Finance has issued Portaria MF no. 488/2014, on December 1, which reduced the maximum income tax rate from 20% to 17% for the purposes of applying the concepts of tax havens and privileged tax regimes. December 08, 2014

Swedish Tax Agency reviews TP legislation and proposes changes

The Swedish Tax Agency has, on request by the Swedish Government (Ministry of Finance), evaluated the transfer pricing documentation rules’ functionality and proposed possible changes to simplify the application. December 08, 2014

The dangers of creating an accidental PE and how to avoid it

As companies’ employees become more globally mobile, there is an increasing risk that a permanent establishment (PE) may occur unintentionally, leaving taxpayers at risk of taxable income liabilities. November 28, 2014

Determining the transfer pricing policy for liquefied natural gas

Tamir Druz, a director at Capra Energy Group, discusses the best methods for determining an optimal transfer pricing policy for liquefied natural gas (LNG). September 01, 2014

Hong Kong signs first bilateral APA

Hong Kong has agreed its first bilateral advance pricing agreement (APA) since its scheme began in March 2012. EY, who facilitated the deal between Hong Kong and the Netherlands, explain how the process progressed with the authorities. July 10, 2014

Marzen Aluminum ruling based on structuring rather than pricing

The Tax Court of Canada has ruled that, while Marzen Artistic Aluminum provided sales and marketing staff to Starline International (SII) at an arm’s-length price, the documentation presented was insufficient. The ruling is significant because it is the first Canadian decision focusing on the structuring of transactions rather than the pricing. June 26, 2014

Netherlands reclaims Swiss company’s profits and applies penalties in transfer pricing case

The Dutch District Court of Zeeland/West-Brabant ruled, on January 17 2014, on a Swiss Captive Insurance company (without employees), taxing most of its profits back in the hands of a related Dutch taxpayer with 50% penalties. March 18, 2014

Intangible assets in the media and entertainment industries: In depth analysis

The US television production industry reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look at dealing with intangibles. February 18, 2014

The transfer pricing considerations of Suzuki’s 100% subsidiary in India

Car manufacturer, Suzuki, has decided to set up a 100% subsidiary in Gujarat, India, in addition to its majority-owned listed-entity, Maruti Suzuki. Wider business decisions aside, there are transfer pricing implications, which must be considered by any multinational in this position. February 04, 2014

McKesson Canada: CRA wins in Tax Court but taxpayer files with Court of Appeal

The Canada Revenue Agency (CRA) saw pharmaceutical company McKesson’s arguments dismissed by the Tax Court in December 2013 but the company has now filed its arguments with the Federal Court of Appeal. January 24, 2014

How to organise your TP department to avoid dispute

Governments' hard-line approaches to companies' transfer pricing arrangements has resulted in a rise in transfer pricing cases being resolved in court, explains Fabrizio Lolliri, European director of transfer pricing for Hogan Lovells. January 21, 2014

The new cost of global compliance: Private company data for local comparables

All of us in the tax world know that transfer pricing has been a hot topic this year. Around the globe, tax authorities have become more aggressive, primarily to reduce government fiscal deficits. January 20, 2014