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

South Africa

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Santander state aid case may prove crucial to Apple’s appeal

Apple’s €13 billion ($14.8 billion) tax battle could hinge on a little-known Spanish case involving Santander and Autogrill España that has been knocking around the European Commission and courts for a decade. A final decision is expected in months. October 25, 2016

UN updates TP manual for developing countries

The UN Committee of Experts on International Cooperation in Tax Matters has approved changes to its transfer pricing manual and model tax treaty. October 25, 2016

Five new jurisdictions sign the MCAA

Brazil, Guernsey, Jersey, the Isle of Man and Latvia signed the OECD's Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of country-by-country reports bringing the total to 85. October 24, 2016

EU plans common corporate tax for large companies

Leaked documents revealing plans for a new tax law affect two-thirds of EU businesses and require large companies to pay taxes on a common set of revenues and reductions. October 24, 2016

OECD releases BEPS Action 14 documents

The OECD has released key documents that will form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan. October 21, 2016

News Briefs for October 20, 2016

The latest transfer pricing news includes the updated Chinese APA programme, Indonesian plans for a lower tax rate, and UK concerns on proposed penalties. October 20, 2016

US and Mexico agree on TP framework for maquiladoras

US taxpayers with maquiladora operations in Mexico can now avoid double taxation by entering into a unilateral advance pricing agreement (APA). October 18, 2016

Irish Revenue disputes that Apple tax was below 2%

Ireland plans to tell European authorities on January 2 exactly how much Apple owes in back taxes as it prepares to appeal an order to collect an estimated €13.5 billion euros ($14.8 billion) plus interest. October 14, 2016

UN to update TP manual for developing countries

The UN Committee of Experts on International Cooperation in Tax Matters is considering changes to its transfer pricing manual and model tax treaty. The four-day meeting in New York ends today. October 14, 2016

Netflix reports UK tax as pressure intensifies on MNEs

Netflix, the entertainment streaming service with an estimated 5 million British subscribers, is the third US multinational in a week to reveal how much – or how little – UK corporate tax it pays. October 13, 2016

VIDEO: Are companies ready for CbC reporting?

Multinational companies are faced with a number of issues regarding country-by-country reporting (CbCR), tax advisers say. October 12, 2016

Vietnam releases draft of new TP rules

Vietnam has proposed significant changes to its transfer pricing rules in an effort to battle tax evasion. October 12, 2016

VIDEO: Getting ready for BEPS, the essentials

Taxpayers preparing for a post-BEPS world need to ensure tax and business departments start working together, tax practitioners say. October 10, 2016

Poland introduces 'revolutionary' TP changes

Poland plans substantial changes to TP requirements while advisers report an increasing number of audits. October 10, 2016

Facebook UK tax credit leads to questions

Facebook UK Ltd. ended its fiscal year with a tax credit while eBay (UK) Ltd. paid £1.1 million ($1.24 million), according to financial accounts sparking debate about Britain's treatment of multinationals. October 10, 2016

Canada cracks down on TP abuse with fines, audits

Canada is hiring 100 auditors, increasing financial penalties and hoping to send a strong message about transfer pricing practices with the opening of the Cameco case, the largest TP court battle in Canadian history. October 07, 2016

World Bank seek to fill gap left by OECD

The World Bank is releasing a handbook for developing countries to implement and grow transfer pricing regimes. October 07, 2016

Taxpayers struggle to win tax disputes in Brazil

Taxpayers have won less than a third of cases in Brazil’s Carf (conselho administrativo de recursos fiscais) courts since it reopened in December 2015, leading to expensive appeals. October 06, 2016

Donna McComber returns to Baker and McKenzie

The former assistant director of the advance pricing and mutual agreement programme at the IRS in the US has rejoined Baker and McKenzie as a director of economics. October 05, 2016

News Briefs for October 3, 2016

The latest transfer pricing news including updates on Irish bilateral APAs, the OECD's Multilateral Instrument and Costa Rica's TP regulations. October 03, 2016

Cameco transfer pricing case to start in Canada

Cameco heads to court this week over a potential C$2.2 billion (US $1.68 billion) tax bill involving its Swiss subsidiary in one of the largest transfer pricing disputes in Canadian history. October 03, 2016

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

Developing countries eye tech companies for new taxes

Indonesia, Japan and Thailand are targeting tech companies like Google and Apple as developing countries hunt for tax revenue. 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

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