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UK politicians question Osborne over Google tax deal in wake of Paris raid

The UK's tax deal with Google came under scrutiny today after Google’s Paris office was raided by French authorities in a tax investigation over an estimated €1.6 billion ($1.8 billion). The raid was part of a probe that stretches from France to Ireland and dates back to June 2015. Google said it was working with authorities. May 25, 2016

Transfer Pricing: 'Broad-based' control concept pursuant to Italian courts

Article 110, paragraph 7 of the TUIR (i.e., Italian Income Tax Code, hereinafter, “TUIR”), related to the Italian Transfer Pricing regime, establishes that in order for the above rule to be applicable, one of the companies involved in the intercompany transaction must exercise control over another company, or that both be under common control. May 25, 2016

ITR Global Transfer Pricing Forum – Berlin, June 29 & 30

Almost a year after the final BEPS guidelines were released, some companies are still struggling to come to grips with the OECD’s recommendations. May 24, 2016

IRS targeting SMEs for transfer pricing audits

The Internal Revenue Service has shifted its attention to transfer pricing audits of smaller US companies that it may have previously ignored, tax experts warn. May 24, 2016

In focus: The Philippines grapples with transfer pricing

TP Week embarks on a new series of features looking at up-and-coming jurisdictions for transfer pricing. These countries have only recently created transfer pricing legislation but are trying to catch up with other jurisdictions. This week, the Philippines is in the spotlight. May 23, 2016

Ireland denies giving Apple sweetheart tax deal

Ireland did not provide Apple with state aid or any other kind of special tax deal, Finance Minister Michael Noonan told parliament in a response to questions about the long-running European investigation which has cost the Irish government at least €300,000 ($336,000) in legal fees. May 21, 2016

ITAT’s Vodafone appeal drags litigation “too far”

The Delhi Supreme Court will hear the Income Tax Department's (ITAT) appeal against the Bombay High Court’s rejection of an ITAT transfer pricing adjustment against Vodafone. The move has advisers questioning India’s tax-friendly environment for foreign investors. May 19, 2016

US group urges Congress to stop OECD funding over 'anti-American' BEPS bias

As the US prepares to adopt country-by-country reporting by July, lobbying efforts are underway to stop what anti-BEPS campaigners describe as: ‘onerous and excessive new reporting requirements’ and a ‘massive tax grab’ that undermines Americans. May 18, 2016

China, Germany, UK top list of concerns for multinationals filing CbCR data

Taxpayers are worried about how China, Germany and the UK will use data provided in country-by-country reports (CbCR), according to a survey by TP Week in conjunction with Thompson Reuters. Other fears include concerns about increased audit risks and confidentiality breaches. May 17, 2016

Ilva state aid probe expanded to include Italian steelmaker’s €300 million loan

The European Commission (EC), already investigating Italian steelmaker Ilva over €2 billion ($2.27 billion) in Italian financing, has extended its state aid probe to look into another loan made in December 2015. May 16, 2016

NEWS BRIEFS for May 16 2016

The latest headline news from Transfer Pricing Week includes: MEP calls for more action to fight aggressive corporate tax planning by multinationals; AG opinion in Masco Denmark and Damixa case involving freedom of establishment; US Treasury official Robert Stack's view of BEPS negotiations targetting US multinationals; India Vodafone case heads to the Supreme Court; and the IRS releases a practice unit involving section 482. May 16, 2016

David Cameron calls on US, China to create beneficial ownership registries in push for transparency

Prime Minister David Cameron has called on the US and China to create company registries, saying larger countries needed to catch up with UK overseas territories and crown dependencies. Cameron was addressing an anti-corruption summit in London – a summit that the media noted was not attended by the British Virgin Islands. TP Week reporter Joelle Jefferis was with the Prime Minister at the conference. May 12, 2016

China, India, sign up to CbCR, bringing the total number of countries to 39

The Multilateral Competent Authority (MCAA) agreement signed today will allow the six new signatories - China, India, Canada, Iceland, Israel and New Zealand - to exchange country-by-country reports with other like-minded countries and help tax administrations improve their understanding of how MNEs structure operations. May 12, 2016

Corporate transparency: ‘not just an end in itself’

While European politicians are pushing for more tax transparency, multinational companies - tired of regulation for the sake of it - are starting to push back. TP Week reports from the Commonwealth Secretariat conference. May 12, 2016

The OECD's new patent box regime: trouble ahead?

The OECD takes a dim view of a practice that allows companies to take advantage of low tax rates without actually supporting IP with economic substance. None-the-less patent boxes are still attracting plenty of attention in Europe. Do the OECD's new guidelines put an end to the problem, or do they create an even bigger monster? May 12, 2016

Norway moves closer to strengthened CbCR; unveils revised 2016 budget

Norway’s new draft regulations related to country-by-country reports are to be submitted to parliament later this month, according to a BEPS update presented to parliament by the finance minister. Changes could be in place by 2017. May 11, 2016


The latest headline news from Transfer Pricing Week include: EU Commission releases decision on Belgium’s excess profits tax regime after five months; New Zealand sees 'explosion' of foreign trusts from South America; and London gets ready to host anti-corruption conference. May 10, 2016

Panama Papers searchable database of company information goes live

Financial advisers, lawyers and company officers may find uncomfortable reading after the International Consortium of Investigative Journalists (ICIJ) released a searchable database of offshore entities linked to the 11,500 leaked ‘Panama Papers’. May 09, 2016

Asia tax and transfer pricing awards: Winners announced

International Tax Review and TP Week’s Asian tax awards took place on May 5 at the Goodwood Park Hotel in Singapore. May 09, 2016

Technology, Media and Telecommunications Forum May 18 & 19

Legal and tax issues are among the key challenges facing TMT professionals and the focus of the Technology, Media and Telecommunications Forum to be held May 18 & 19 at the Hotel Pullman London St Pancreas. May 09, 2016

What Australia can learn from the UK’s DPT

Australia proposed a new diverted profits tax (DPT) in its 2016-2017 Budget that closely resembles the UK system. Will the same policy in a different jurisdiction bring different results? May 06, 2016

Australia v UK: Diverted Profits Tax Strategy

The Australian government's DPT proposal closely resembles the UK's DPT. TP Week looks at how similar the plan and potential results are. May 06, 2016


The latest headline news from Transfer Pricing Week include: Norway's plan to cut corporate tax; new 'Panama Paper' corporate documents to be released; US Treasury rules on 'earnings stripping' cost Coca-Cola; HMRC tax avoidance scheme pay dividends and Danish authorities turn to ADR in transfer pricing disputes. May 06, 2016

Judge dismisses FATCA challenge brought by US Sen. Rand Paul

US Senator Rand Paul and several others have lost a court challenge to the US Foreign Account Tax Compliance Act (FATCA) for failing to show the law had harmed them or was likely to do so. May 05, 2016

European Tax Awards 2016 - the shortlist is out

The European Tax Awards have been a highlight of the social calendar since 2005. This year's event in London takes place with a dinner on Thursday, May 26 at the Savoy Hotel, and brings together the leading international tax and transfer pricing professionals from across Europe. May 05, 2016

Britain may have overstepped its powers by trying to impose CbCR anti-avoidance regulations

The UK may have acted beyond its powers in its push to implement BEPS by including a targeted anti-avoidance rule (TAAR) in country-by-country regulations, according to Britain’s Select Committee on Statutory Instruments. May 04, 2016

Australia Budget introduces Diverted Profits Tax

Multinationals are targeted in Australia’s 2016-2017 budget with Treasurer Scott Morrison aiming to collect an additional AUS $3.9 billion ($2.9 billion) in tax from MNEs by 2020. May 03, 2016

WCO transfer pricing tool to bring certainty in determining duty liabilities

The World Customs Organisation’s (WCO) Technical Committee on Customs Valuation has finalised a tool to improve how authorities manage the interaction of customs and transfer pricing. But the WCO admits it is an ongoing struggle and more work will be needed to improve the environment for business. May 03, 2016


The latest headline news from Transfer Pricing Week. News Briefs include: Turkey preparations for the electronic permanent establishment concept; Australia’s budget plan for diverted profits tax; WCO tool for customs and transfer pricing and BEPS on the agenda at this week’s ABA meeting. May 03, 2016

Ex-PwC employee tells court he had a 'duty' to act on sweetheart tax deals

Raphael Halet, a PwC employee on trial in the so-called ‘LuxLeaks’ tax scandal, said he decided to act after seeing a France 2 television report in 2012, a story it later transpired was based on the alleged leak of 30,000 tax documents by ex-PwC auditor Antoine Deltour. April 29, 2016

Russia issues draft law opening the door to BEPS

Russia’s Ministry of Finance has reportedly issued a draft law that would bring its transfer pricing documentation rules in line with the OECD’s base erosion and profit shifting (BEPS) proposals under Action 13. April 29, 2016

PwC names Kevin Ellis chairman and senior partner in UK, Middle East

Kevin Ellis, 52, currently managing partner, starts his four-year term July 1 when Ian Powell retires. Ellis has been a PwC partner for 20 years and has led in growth areas including cyber security, data and analytics. April 29, 2016

TP WEEK NEWS BRIEFS For April 28, 2016

The latest headline news from Transfer Pricing Week. News Briefs include: Latin America loses $100 million to transfer pricing; EC's Ireland-Apple investigation; ‘LuxLeaks’ whistleblower trial; Australia penalties for corporate tax avoidance; and OECD to address tax avoidance in Kyoto. April 28, 2016

OECD Brexit Report: UK exit from EU would cause 'major shock'

Britain's departure from Europe would be a ‘major negative shock’ to the UK economy, costing each household about £2,200 ($3,200) a month, and the economic fallout would be felt throughout Europe, the OECD said in a report released today, two months before the UK's 'Brexit' referendum. April 27, 2016

TP WEEK NEWS BRIEFS For April 27, 2016

The latest headline news from Transfer Pricing Week. TP News Briefs include: Brexit tax implications outlined at OECD conference in London; Australian fines for firms involved in tax evasion advice; and LuxLeaks trial day two. April 27, 2016

Europe divided over plan for MNEs to publish EU and offshore tax data

Finance ministers are split over EU draft rules requiring multinationals to publish country-by-country tax reports (CbCR), with some politicians urging caution and others warning that Europe is overreacting to the ‘Panama Papers’ uproar. April 26, 2016

Ex-PwC auditor Deltour and two others face prison as ‘LuxLeaks’ trial gets underway

Former PwC auditor Antoine Deltour stands trial in Luxembourg today on charges related to accessing a database of confidential corporate tax deals later published by a French journalist. The whistleblower is accused of theft and breach of professional secrecy, among other charges. April 26, 2016

TP WEEK NEWS BRIEFS For April 25, 2016

The latest headline news from Transfer Pricing Week. TP News Briefs include: the impact of US Treasury plans for earnings stripping on foreign MNEs; Australian deal to fast-track corporate tax cases, Czech Transfer Pricing Inspections; OECD to focus on BEPS; and US IRS meeting on new CbCR rules. April 25, 2016

US anti-inversion rules to have ‘enormous impact’ on foreign MNEs

The US Treasury’s proposed regulations on ‘earnings stripping’ will cause headaches for foreign multinationals, including increased administration, additional costs and limitations with debt leveraging, tax advisors warn. April 25, 2016

Apple co-founder Wozniak says companies should pay 50% tax

Steve Wozniak, co-founder of Apple along with Steve Jobs, said that all companies, including Apple, should pay the same rate of tax as he does personally. April 22, 2016

India FM: Vodafone appeal is unrelated to retrospective taxation

Finance Minister Arun Jaitley has defended India's decision to appeal a Bombay High Court ruling in the Rs 8,500 crore ($1.7 billion) Vodafone transfer pricing case, saying it is not related to a separate, retrospective tax issue. April 21, 2016

The Platform for Collaboration on Tax: The same old story?

The world's largest multilateral organisations laid out plans for a joint ‘platform’ to help developing countries fight tax evasion, the first steps toward creating international standards. Tax campaigners aren’t convinced that the announcement actually assists developing countries. April 21, 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

UN tax committee publishes draft transfer pricing manual

The UN Committee of Experts on International Cooperation in Tax Matters will consider its draft Transfer Pricing Manual for Developing Countries at its eighth session in Geneva from October 15-19. October 03, 2012

Norway transfer pricing documentation guide

Hans-Martin Jørgensen and Michael Vorndran of Deloitte August 09, 2012

Austria transfer pricing documentation guide

By Andrea Lahodny and Gabriele Holzinger of Deloitte August 08, 2012

Greece transfer pricing documentation guide

By Stefanos Mitsios of Ernst & Young August 08, 2012

Indonesian transfer pricing documentation guide

By Permana Adi Saputra of PB Taxand August 08, 2012

Malaysia transfer pricing documentation guide

By Bernice Tan of Taxand Malaysia August 08, 2012

Denmark transfer pricing documentation guide

Tim Holmes and Thomas Bjerre of Ernst & Young Copenhagen outline the approach to the transfer pricing documentation requirements in Denmark. August 03, 2012

US transfer pricing documentation guide

By Kathrine Kimball and Minjung Kim of Charles River Associates July 26, 2012

UK transfer pricing documentation guide

By Graham Head (Senior Manager) and Liz Hughes (Transfer Pricing Director), Grant Thornton UK July 24, 2012

South Korea transfer pricing documentation guide

By Taehyung Kim of Deloitte July 23, 2012

HMRC is exchanging unilateral APA information with treaty partners

HMRC is exchanging the terms of its unilateral advance pricing agreements (APA) with UK tax treaty partners. The measure is part of the revenue’s drive towards greater transparency and began this month. February 26, 2013

How to survive a transfer pricing audit in India

Hardev Singh and Saurabh Dhanuka, of KPMG, TP Week’s correspondent in India, give practical advice on dealing with India’s revenue authorities May 22, 2008

How to survive a transfer pricing audit in Malta

Mirko Rapa, of PricewaterhouseCoopers in Valetta, explains the environment for transfer pricing audits in Malta April 15, 2008

How to survive a transfer pricing audit in the Czech Republic

Jiri Teichmann and Libor Fryzek of Ernst & Young in Prague provide insight into the transfer pricing audit process April 07, 2008

How to survive a transfer pricing audit in China

Glenn DeSouza and Qian Min looks at the impact of April 2008 guidelines on the conduct of transfer pricing audit April 06, 2008

How to survive a transfer pricing audit in Poland

Mike Ahern and Piotr Wiewiorka, of PricewaterhouseCoopers in Warsaw, outlines the approach to transfer pricing audits in Poland March 14, 2008