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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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The TP changes you need to know about in South Africa’s budget

Finance minister Pravin Gordhan needs to find ZAR 28 billion ($2.1 billion) to plug the deficit in South Africa’s revenue. This might mean transfer pricing changes in tomorrow’s budget. February 21, 2017

Automatic information exchange comes to Italy

Antonella Della Rovere and Filipa Correia of Valente Associati GEB Partners look at Directive 2015/2376/EU and its implementation in Italy. February 21, 2017


Are taxpayers ready for Hong Kong’s TP regime?

Hong Kong’s transfer pricing rules are ambiguous and not codified in law, but with a new regime under way, are taxpayers ready for sweeping changes? February 16, 2017

Pascal Saint-Amans pleased with progress on automatic sharing of CbC information

With more jurisdictions signing up to the OECD’s tax co-operation agreement to enable the automatic sharing of country-by-country information, Pascal Saint-Amans tells TP Week that the new measures are proving effective. February 15, 2017


Australia’s diverted profits tax could spark a global trend

On February 9, the Australian Parliament introduced a bill including a diverted profits tax (DPT). Could other countries looking to shore up their tax bases follow suit? February 14, 2017

Swiss voters resoundingly refuse to foot the bill for multinational tax sweeteners

In what will likely prove to be Switzerland’s most important referendum of 2017, voters overwhelmingly refused to back Corporate Tax Reform III in a sign they are not willing to see Switzerland’s status as a tax haven cemented if they have to pay for it. February 14, 2017


Resource curse: The TP uncertainties facing mining groups in 2017

Since the OECD’s BEPS Project was launched in October 2015, many industries are having to adjust to the new environment. A new Deloitte report found that the mining sector, with its long-term investments in developing countries, could be particularly vulnerable to tax changes. February 09, 2017

Swiss taxpayers eagerly eye knife-edge corporate tax reform referendum

Switzerland could be set for sweeping change if voters approve Corporate Tax Reform III. What do the proposed measures mean for taxpayers? February 07, 2017


More companies will leave Luxembourg, says finance minister

Luxembourg’s finance minister expects more companies to follow the lead of McDonald’s and relocate their tax bases amid increased scrutiny from European tax authorities. February 07, 2017

Luxembourg’s sharpened tax rules for intra-group financing

On December 27 2016, the Luxembourg Tax Authorities (LTA) published a circular, L.I.R. no 56/1 – 56bis/1 (Circular) designed to position the seminal principles of the OCED TP Guidelines (i.e. the arm’s-length principle, comparability and substance over form) as the framework of reference when establishing the capital structures and the remunerations of financing vehicles in Luxembourg. With an effective date of January 1 2017, the Circular has left virtually no time for taxpayers to adjust to this new paradigm while many questions regarding the scope, implementation and implications remain unanswered. February 03, 2017


OPINION: Is a race to the bottom really in corporate interests?

Companies have long been lobbying for lower corporate tax rates. But the consequences of going too far might not be in their interests in the long-term. February 02, 2017

India’s 2017 budget: TP highlights and lowlights

India’s finance minister, Arun Jaitley, introduced two new measures in the 2017 budget, secondary adjustments and thin capitalisation rules, but taxpayers have been left nonplussed. February 02, 2017


OECD invites taxpayer input on MAP

Action 14 of the OECD’s BEPS Project aims to make dispute resolution mechanisms more effective. The Organisation is inviting taxpayers from seven more countries to discuss issues related to the mutual agreement procedure (MAP). January 31, 2017

Russian and Indonesian taxpayers fear automatic sharing of CbC information

Five more jurisdictions signed up to the OECD’s tax co-operation agreement to enable the automatic sharing of country-by-country information. But among taxpayers in the largest of these economies, advisers report concerns. January 31, 2017


How to help developing countries with transfer pricing: The Platform for Collaboration on Tax wants to hear from you

Developing countries have long struggled with transfer pricing. The Platform for Collaboration on Tax has drawn up a draft toolkit to help them and it is inviting feedback from stakeholders. TP Week speaks to leading figures behind the Platform and business and NGO critics to get their view. January 26, 2017

Compliance relief for Singaporean businesses

Singapore’s tax authority has released new guidelines that will make life easier for Singaporean taxpayers, as they can now rely on indicative margins on their related-party loans below SGD 15 million ($10.5 million). January 26, 2017


Will Trump blow up BEPS?

President Trump enjoys making statements about big league tax reforms that will ensure “the rich pay their fair share”, but seems to choke up when it comes to his own tax affairs. Are BEPS and transparency in safe hands? January 24, 2017

Patience and prayer for India’s Budget: Are taxpayers ready for GAAR?

India’s GAAR has been long delayed, but with next week’s Budget unlikely to offer taxpayers further reprieve, it is time for them to get ready. January 24, 2017


New North American TP leader at Duff & Phelps

Duff & Phelps has promoted one of its managing directors, Jill Weise, to transfer pricing group practice leader for North America. January 20, 2017

Microsoft among MNEs facing greater scrutiny in New Zealand

Microsoft’s New Zealand unit is one of several companies that will be subjected to a transfer pricing audit as the tax authority ramps up its scrutiny of the technology sector. January 19, 2017



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