OECD’s Work on Harmful Tax Practices on Track

OECD’s Work on Harmful Tax Practices on Track

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The OECD has published a report covering the assessment of 53 preferential tax regimes as part of its work under base erosion and profit shifting (BEPS) Action 5, on harmful tax practices.
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Mutual Agreement Procedure Statistics Published for 2017

Mutual Agreement Procedure Statistics Published for 2017

The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.

According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading

Transfer Pricing Regulations Revised in Nigeria: Some Highlights

Transfer Pricing Regulations Revised in Nigeria: Some Highlights

By Amaka Samuel Onyeani (Senior Manager, Transfer Pricing, Andersen Tax, Nigeria) & Abisola Agboola (Assistant Manager, Transfer Pricing, Andersen Tax, Nigeria)

Nigeria’s Federal Inland Revenue Service (FIRS) recently released the revised Income Tax (Transfer Pricing) Regulations, 2018 (the Transfer Pricing Regulations). The Transfer Pricing Regulations are one of the efforts of the FIRS in improving the administration of transfer pricing in the country, increasing revenue collection via taxes, and protecting Nigeria’s tax base.Continue Reading

OECD Transfer Pricing Profiles for 7 More Countries Published

OECD Transfer Pricing Profiles for 7 More Countries Published

The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa, and Turkey. The OECD has also updated the information contained in Singapore’s profile.Continue Reading

Switzerland Adopts Dispatch on BEPS Convention

Switzerland Adopts Dispatch on BEPS Convention

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Swiss Federal Council on Wednesday adopted the dispatch on the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading

Nigeria CbC Reporting Tax Regulations Explained

Nigeria CbC Reporting Tax Regulations Explained

By Josh Bamfo (Partner & Head, Transfer Pricing Services, Andersen Tax, Nigeria)

The Federal Government of Nigeria finally published the much anticipated Income Tax (Country-by-Country Reporting) Regulations, 2018 (the CbC Regulations) on June 19, 2018 (with a commencement date of January 1, 2018). This is in line with Nigeria’s signing of the OECD’s Multilateral Competent Authority Agreement on January 27, 2016, providing for automatic exchange of CbC reports.

As a sequel to my earlier publication on the potential implications of the draft CbC reporting Regulations to affected taxpayers, which was published four months ago, this article presents the key highlights of the CbC reporting Regulations and re-assesses the potential implications based on the content of the final, published version.Continue Reading

South Africa’s 2018 Budget: Unpacking International Tax Measures

South Africa’s 2018 Budget: Unpacking International Tax Measures

By Ahmed Jooma (Independent Tax, Legal, and Public Policy Consultant)

On February 21, 2018, South Africa’s Finance Minister, Malusi Gigaba, presented the country’s National Budget, which will be tougher on the populace than on multinational corporations. Most of the tax changes that will affect cross-border transactions are of a technical nature. A continued focus on base erosion and profit shifting is expected to assist in arresting the deteriorating fiscal environment. This is further exacerbated by pressure to maintain a relatively low corporate tax rate in the face of tax competition.
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Ireland, Ghana Sign New Tax Treaty

Ireland, Ghana Sign New Tax Treaty

Ireland and Ghana signed a new tax treaty on February 7, 2018. The procedures to ratify the treaty are underway.

Ireland is also negotiating and renegotiating existing treaties with foreign jurisdictions.

 According to the tax authority, Ireland’s existing treaty base will also be updated to incorporate provisions set out in the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.

CbC Reporting Regulations in Nigeria: Potential Implications For Taxpayers

Joshua Bamfo of Andersen Tax discusses CbC Reporting Regulations in Nigeria

By Josh Bamfo (Partner & Head, Transfer Pricing Services, Andersen Tax, Nigeria)

Since the signing of the Multilateral Competent Authority Agreement by the Federal Inland Revenue Service (FIRS) and its subsequent ratification by the Federal Executive Council in 2016, most Nigerian taxpayers and tax practitioners have been keenly waiting for the implementation of a country-by-country (CbC) reporting requirement, developed under Action 13 of the base erosion and profit shifting (BEPS) project. Nonetheless, we were still surprised by the FIRS’ communication via its official Twitter handle on 24 January, 2018, that the Income Tax (Country-by-Country Reporting) Regulations, 2018, (CbC Regulations) has now been signed by the Federal Government of Nigeria, and will be gazetted soon.Continue Reading

Panama, Malaysia, Four Others Sign OECD’s BEPS Convention

Tax administration commit to exchanging CbC reports

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama, and Tunisia have newly signed the base erosion and profit shifting (BEPS) Multilateral Convention, the OECD announced on January 24, 2018.Continue Reading

New South Africa Tax Guidance on Prohibition of Deductions for “Tainted” IP

South Africa guidance on prohibition of deductions for tainted intellectual property

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The South African Revenue Service has issued detailed guidance on the interpretation and application of section 23I of the Income Tax (IT) Act, which relates to the prohibition of deductions for “tainted” intellectual property (IP).Continue Reading