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

South Africa

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NEWS BRIEFS for June 27

The latest news from TP Week includes Ireland's new APA programme; an update for US-Luxembourg tax treaty; and the OECD's Kyoto meeting. June 27, 2016

Brexit: The referendum of a generation that will change Europe forever

The UK will be free to pursue its own direction with tax and transfer pricing legislation now that Britain has voted to leave the European Union, but the nation is unlikely to break all ties. June 24, 2016

New guidance on Greek TP documentation for mergers by absorption

The General Secretariat of Public Revenues in Greece issued a new Ministerial Circular on June 6, which refers to the application of transfer pricing documentation rules in cases of mergers by absorption, realised according to the provisions of Law 2166/1993 concerning business restructurings. June 23, 2016

Brexit: tax implications for business

If the UK votes to leave the EU the country may be able to draft its own tax and TP legislation. But will it really be free from the restraints of EU directives or the jurisprudence of the Court of Justice of the European Union? June 22, 2016

Multinationals nervous as UK's 25% DPT tax deadline looms

HMRC's Diverted Profits Tax could be a game-changer for many businesses operating in the UK. June 22, 2016

NEWS BRIEFS for June 21

The latest headline news includes: EU anti-avoidance tax powers; Microsoft's UK APA issues; and Finnish transfer pricing documentation regulations. June 21, 2016

OECD amends transfer pricing guidelines

The OECD's transfer pricing guidelines have been changed, affecting many countries and the basis of APA and MAP agreements. June 16, 2016

Japanese ambassador says Indian TP a “main concern”

Kenji Hiramatsu, the Japanese Ambassador to India has highlighted Japanese concerns over Indian taxation, particularly transfer pricing. June 14, 2016

EC publishes controversial Fiat state aid ruling

EU Commission finally releases version of 2015 decision that found Luxembourg’s advance pricing agreement (APA) with a Fiat subsidiary was illegal state aid. June 10, 2016

EP calls for common rules for patent box tax reductions

Plans for an EU anti-tax avoidance directive were welcomed by members of the European Parliament this week but politicians were hungry for more. June 10, 2016

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

A rush of international taxation followed the OECD's BEPS recommendations but did it bring the promised clarity and consistent tax reform? June 09, 2016

State aid: The secretive world of transfer pricing probes

Authorities have sifted through 1,000 tax rulings to examine the methods behind state aid decisions. But are European officials overstepping their powers? June 09, 2016

EP votes to investigate Panama Papers scandal

The European Parliament Conference of Presidents agreed on plans to set up a ‘Panama Papers’ inquiry and appoint 65 members to investigate offshore tax avoidance. June 08, 2016

MEPs debate new measures to fight tax avoidance

MEPs sit down on Tuesday to discuss new tactics to fight tax avoidance, which EU countries estimate cost them €160-190 billion ($180-4216 billion) a year. June 07, 2016

NEWS BRIEFS for June 7 2016

The latest headline news includes: HMRC sees drop in high-value transfer pricing investigations; Romania becomes BEPS associate; and Austria moves closer to draft transfer pricing documentation June 07, 2016

FEE: European anti-avoidance tax directive could hurt companies

The Federation of European Accountants (FEE) is lobbying the EU to rethink its proposed anti-avoidance tax directive, arguing that it could be ‘very damaging’ for some companies and a burden on European economies. June 06, 2016

Enter now for the Americas Tax Awards 2016

Private-practice, in-house and individual awards are up for grabs at this year's Americas Tax Awards. June 06, 2016

KPMG India: Rahul Mitra to lead the transfer pricing practice

Rahul Mitra, a specialist in transfer pricing for more than two decades, has been appointed KPMG India’s head of transfer pricing effective today. June 06, 2016

Women in Tax leaders guide – nominate now

This is your chance to nominate the leading women in the tax advisory world. The submission period is now open. June 03, 2016

Brexit: Multinationals could face extra costs on transfer pricing

Multinationals could shoulder additional costs of managing transfer divergent transfer pricing legislation if Britain leaves the European Union, advisers warn. June 03, 2016

OECD appoints EY's VanderWolk head of TP division with key BEPS role

Jefferson VanderWolk has been appointed as the new OECD head of the tax treaty, transfer pricing and financial transactions division in the Centre for Tax Policy and Administration. June 02, 2016

OECD calls for comment on BEPS Action 15 multilateral instrument

The OECD has asked for comment on technical questions and other matters on the multilateral instrument for use by countries implementing BEPS tax measures and by June 30. June 02, 2016

NEWS BRIEFS for May 31 2016

The latest headline news from TP Week includes: EU ministers postpone talks on corporate tax avoidance; French prosecutors hope to analyse Google data within months; and UK considers secondary adjustment rule May 31, 2016

European Tax and Transfer Pricing Awards 2016 – the winners' list is out!

Deloitte won the European Transfer Pricing Firm of the Year at the International Tax Review’s European Tax Awards on May 26. Baker & McKenzie won for European Tax Firm of the Year. Read on for the list of winners. May 27, 2016

European Council issues directive promising CbCR across the EU

The European commission’s anti-tax-avoidance package has been approved and a directive issued to EU member states to implement country-by-country reporting. May 26, 2016

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). 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

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