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

South Africa

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Facebook potentially facing $5 billion tax bill

A US Internal Revenue Service (IRS) investigation into Facebook could land the technology company with a bill that would have “material adverse impact” on the company’s finances. July 29, 2016

Clarification on Greek transfer pricing documentation: Issues with tax adjustments and REICs

Greece’s General Secretary of Public Revenues has issued two decisions to further clarify the application of documentation rules in cases of tax adjustments, as well as the issue of whether Real Estate Investment Companies (REICs) are liable companies for transfer pricing purposes. July 28, 2016

The transfer pricing implications of Brexit

The UK’s decision to leave the European Union could have two significant impacts on the transfer pricing environment in the UK: freedom from the relevant EU Directives, and movement of companies or financial and other assets, either into or out of the UK. July 27, 2016

EXCLUSIVE: OECD's Hickman on BEPS and his departure from the TP unit

Andrew Hickman, former head of the transfer pricing unit, left the OECD in June. In this exclusive interview, he discusses the trials and tribulations of BEPS and why there is never a good time to leave the OECD. July 22, 2016

BEPS: The Global Transfer Pricing Forum in New York

BEPS is transforming multinationals and the 16th annual ITR Global Transfer Pricing Forum in New York will examine varying tax authority approaches; pitfalls for taxpayers; and OECD updates. July 21, 2016

Ireland’s retroactive exchange of information regime

The Irish Revenue Commissioners (Revenue) has confirmed that Ireland’s spontaneous exchange of information regime (the regime) will apply to certain tax rulings issued as far back as January 1 2010. July 20, 2016

Transfer pricing documentation: mandatory requirements in Belgium

On July 4 2016, the Belgium government adopted a law introducing statutory transfer pricing documentation requirements for certain taxpayers. July 18, 2016

NEWS BRIEFS for July 14

The latest headline transfer pricing news including an update on the Apple State aid case; BEPS Action 4 and the anti-tax avoidance directive. July 14, 2016

US Treasury Secretary in Brussels as Apple tax ruling looms

US Treasury Secretary Jack Lew is in Brussels for talks with the European Commission's anti-trust chief Margrethe Vestager as investigators prepare to rule on Ireland’s tax deal with Apple. July 12, 2016

IRS sues Facebook over IP rights transferred to Ireland

The US Internal Revenue Service is investigating whether Facebook undervalued intellectual property rights by billions of dollars in an IP transfer to Dublin. July 11, 2016

European Commission releases Starbucks tax ruling

The European Commission has published its nine-month-old ruling involving Starbucks and its tax agreements with Netherlands, shedding further light on the murky world of State aid investigations. July 11, 2016

Transfer pricing audits: The approach by Italian tax authorities

Within Europe, policies have been developed to enable the free circulation of people, goods and services. Alongside this, steps have been made towards greater interconnection between the tax systems of different countries. July 08, 2016

OECD holds Paris talks as deadline for Multilateral Instrument nears

The OECD is pushing ahead with plans for a multilateral instrument by year-end to help implement tax treaty-related BEPS measures – one of the most contentious of the BEPS Action proposals. July 07, 2016

BEPS survey: Tax departments are juggling resources

Many companies adjusting their tax departments for a post-BEPS world say they don't yet have enough resources to deal with the extra work. July 07, 2016

Initiating your APA in Ireland

Ireland has introduced a formal bilateral advance pricing agreement (APA) programme which came into effect on July 1 2016. It may now be preferable to initiate your bilateral APA in Ireland. July 04, 2016

NEWS BRIEFS for July 3

The latest headline transfer pricing news including the US update on CbCR, new agreement between India and Cyprus, and further OECD guidance on CbCR July 04, 2016

Argentina and four other countries sign MCAA

Five new countries have signed the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country reports (CbCR) under BEPS. June 30, 2016

Amadeus in Indian AMP dispute

Taxpayers in India face uncertainty about how to account for advertising, marketing and promotion expenditure in transfer pricing, as the Supreme Court accepts the tax authority’s appeal on Amadeus India’s AMP arrangements. June 27, 2016

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

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