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

South Africa

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Belgium publishes TP documentation forms and instructions

Forms and further instructions on Belgium’s transfer pricing rules have been published in the Official Gazette on December 2 to comply with the Programme Law of July 1 2016 that introduces mandatory transfer pricing documentation in line with OECD BEPS Action 13. December 02, 2016

PwC adds two new transfer pricing principals

PwC has added two new transfer principals to their US offices, with Jerry Klopfer joining in Boston and Stephen Curtis in Denver. December 01, 2016

Bulgarian transfer pricing regulations

Bulgaria fully applies the OECD Transfer Pricing (TP) Guidelines and has had robust TP rules for several years, but taxpayers should be aware of the regulations. November 30, 2016

Autumn Statement 2016: The transfer pricing impact

In a blow to businesses, the UK government will not delay its plans to implement restrictions on interest deductions and corporate tax relief for historic losses. November 24, 2016

What will the Autumn Statement mean for transfer pricing?

UK Chancellor Philip Hammond is to deliver his first Autumn Statement on November 23, the first major fiscal announcement following the Brexit vote. What do experts expect on transfer pricing? November 22, 2016

Italy’s anti-BEPS struggles

The OECD-recommended measures to counter tax evasion have been integrated in the language routinely used by tax advisers, businessmen and by other interested parties as well. Without implementation however, it would be much ado about nothing. November 21, 2016

Greece amends TP documentation rules and APAs

Law 4410/2016 introduced amendments on the Greek Code of Tax Procedures and, among other issues, on TP Documentation Rules (article 21 Law 4174/2013) and the legal framework for Advanced Pricing Agreements (art. 22 L. 4174/2013). November 21, 2016

News Briefs for November 21, 2016

The latest transfer pricing news includes stories from Nairobi, India, France, New Zealand and Denmark. November 21, 2016

Free webinar: Managing global TP reporting requirements

Join our webinar on November 28 as specialists and economists share their expertise on regulatory developments and how to manage global TP documentation requirements. November 18, 2016

Albanian transfer pricing regulations

Transfer pricing (TP) rules have been present for more than a decade in the Albanian Corporate Income Tax (CIT) Law, but specific and detailed regulations on the application of these rules were only published in the Official Journal No. 70, dated May 20 2014. These changes have totally transformed Article 36 of the Law on Income Tax (No. 8438, dated December 28 1998) by adding seven more provisions on specific rules and actions. November 17, 2016

Free global transfer pricing webinar on the practical strategies for managing BEPS Action 13

Join a panel of transfer pricing experts on December 8, as they share invaluable insights and takeaways on how to manage the challenges arising from BEPS Action 13. November 17, 2016

US MNEs eye planned tax break on repatriated foreign profits

US multinationals that have kept an estimated $2.5 trillion of their foreign profits abroad may benefit from a massive tax break on those earnings under Donald Trump’s presidency. November 15, 2016

Will a Trump presidency end US corporate inversions?

Donald J. Trump, US president-elect and future commander-in-chief, has pledged to curb 'job-killing corporate inversions' by reducing the US business tax rate from 35% to 15%. But will his tax plan work? November 09, 2016

Brexit: UK's Supreme Court to hear arguments in December

The UK’s highest court will convene on December 5 to hear the government's arguments against allowing MPs to vote on triggering Brexit. Debate over the best way to exit the European Union has multiple implications for tax and transfer pricing. November 08, 2016

Facebook IRS case: Inside a multi-billion dollar TP dispute

USA v Facebook is about Big Law and big numbers. Since US tax authorities started auditing Facebook, the IRS has sent 200 requests for documents, interviewed nine Facebook employees and requested five extensions to the statute of limitations. That was just the warm-up. November 08, 2016

State aid decisions: The demise of unilateral APAs?

Advance pricing agreements may be decreasing in popularity. Some advisers report that multinationals are worried unilateral agreements do not provide enough certainty following the European Commission’s state aid rulings. November 08, 2016

Singapore changes related party transactions filing

Singapore will require taxpayers to file details of related-party transactions should the value in audited accounts exceed S$15 million (US$10.8 million). November 07, 2016

IRS appeals knock billions off proposed TP/tax adjustments

The US Treasury Inspector General for Tax Administration (TIGTA) has criticised the IRS for operating in an inconsistent manner during tax and transfer pricing evaluations that were sometimes overturned on appeal. November 07, 2016

World Transfer Pricing directory launched online

World Transfer Pricing, TP Week’s directory to the world’s leading transfer pricing practices, is now online. November 02, 2016

EC proposal for hybrid mismatches will affect MNEs

The European Commission (EC) has released a plan to address hybrid mismatches with non-EU countries, which could have consequences for the taxation of multinationals. November 01, 2016

Trinidad & Tobago to probe Atlantic LNG's Transfer Pricing

Trinidad and Tobago are hiring international consultants to examine transfer pricing related to energy producer Atlantic LNG, Finance Minister Colm Imbert has told the Senate. November 01, 2016

Nordic taxpayers fear CbCR laws will trigger multiple audits

Sweden and Finland have issued bills to implement country-by-country reporting (CbCR) legislation and Norway is awaiting parliamentary approval, creating anxiety for taxpayers. October 31, 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