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

Brazil
0%
Russia
30%
India
30%
China
30%
South Africa
10%


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Australia’s CbCR exemptions

The Australian Taxation Office (ATO) has released guidance on how multinationals could be considered for exemptions from submitting country-by-country reports in the jurisdiction. September 29, 2016

The growing grab for technology giants' taxes

Global pressure is growing on technology companies as Indonesia, Japan and Thailand target the likes of Google and Apple with large tax bills, showing that it is not just Europe that should concern corporations as developing countries hunt for taxes. September 27, 2016


Baker & McKenzie grows its London TP team

Baker & Mckenzie in London have expanded its tax practice by hiring new transfer pricing partner, Steve Labrum. September 26, 2016

Profile: The driving force of Margrethe Vestager

Margrethe Vestager is known for taking items out of her friends’ shopping baskets if she feels they are making the wrong decision. The EU competition commissioner is not short of opinions when it comes to the world’s most powerful companies either – routinely provoking disagreements with major corporations. September 22, 2016


Bird & Bird enters TP agreement with Questro International

The international law firm expands its European transfer pricing offering in a cooperation agreement with the TP boutique. September 22, 2016

EC opens new investigation into Luxembourg’s tax rulings

The European Commission has expanded its investigations into so-called “sweetheart deals” as it looks at the tax rulings between Luxembourg and a French electric utility company. September 21, 2016


Italian Revenue Office clarifications on CFC rules

After the Italian Revenue Office issued new guidance on CFC regulations, Piergiorgio Valente from Valente Associati GEB Partners reviews the changes. September 21, 2016

VIDEO: Americas Tax Awards 2016

Deloitte took top honours as North America Transfer Pricing Firm of the Year at an elegant awards ceremony in New York at the Pierre Hotel on September 15. A full list of the tax and transfer pricing winners can be found here. September 16, 2016


Pakistan to access country-by-country reports

Pakistan will sign a tax Convention on September 14 allowing it to access country-by-country reports from more than 100 jurisdictions, leading to questions about confidentiality and data control in developing countries. September 14, 2016

Billionaire tax disputes: Top five US transfer pricing feuds

There are several blockbuster transfer pricing disputes underway in the US. As Apple fights an eye-watering $14.5 billion tax penalty in Europe, TP Week examined five of the largest US TP feuds with billions at stake. September 12, 2016


Grant Thornton hires TP managing partner

Glen Marku has joined the firm as a managing director in the Transfer Pricing practice, based in Chicago, and Derek Han (pictured) has joined the Cyber Risk practice. September 12, 2016

BDO appoints global transfer pricing head

Zara Ritchie is promoted to BDO head of global transfer pricing as the firm anticipates a year of cross-border mergers and BEPS-related complications. September 08, 2016


Ireland's parliament votes on $14.5 billion Apple tax appeal

Ireland's parliament has held an extraordinary 10-hour debate to decide whether to appeal a European Commission ruling, or collect €13 billion in back taxes from Apple. September 07, 2016

UK moves closer to public country-by-country reporting

The UK government is on the fast-track to requiring multinationals to publicly reveal where they earn revenue and how much tax they pay. But transfer pricing experts urged caution. September 06, 2016


Global Transfer Pricing Forum Europe 2016: BEPS Report

After the hugely successful Global Transfer Pricing Forum in Berlin in June, TP Week produced a PDF highlighting key concerns and solutions including the rise in TP disputes, coping with BEPS in the digital economy, and CbCR strategies. September 06, 2016

UK to debate public country-by-country reporting

The Finance Bill is on the agenda as British MPs return to work and one of the most heated debates will surround public country-by-country reporting. September 05, 2016


EXCLUSIVE VIDEO: Ireland to decide on €13bn Apple tax

Irish MPs gather in the Dáil on September 7 for the vote of their lives: Who wants to be a billionaire? September 02, 2016

More than 100 countries join OECD tax exchange project

Five more governments have signed up to an OECD project that will see tax authorities worldwide exchange company information. September 02, 2016


New York TP Forum tackles key transfer pricing issues

Multinationals are struggling to deal with BEPS, country-by-country reporting, and issues surrounding their reputations in light of the European Commission’s $14.5 billion ruling against Apple. September 01, 2016

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


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