Indonesia calls global minimum tax a ‘trick’ by developed nations

Indonesian Minister terms global minimum tax a ‘trick’

Indonesia’s Minister of Investment has dismissed the global minimum tax proposal as a self-serving ‘trick’ being pulled by developed nations.Continue Reading

International Tax Law Student Essay Writing Competition 2023

TP News is announcing its first annual International Tax Law Student Essay Writing Competition 2023.

We are now inviting original submissions from students enrolled in a full-time undergraduate law course around the world. Co-authorship is possible.

The submission must seek to identify and answer a point of law that involves interpretation of one or more provisions of a tax treaty. The essay should not be descriptive in nature and must show outstanding analysis, while adding to the existing tax treaty jurisprudence.

We will not accept submissions over 3,000 words. We do not accept footnotes or endnotes, use hyperlinks instead.

All submissions will go through two rounds of selection process. Based on an initial screening by TP News team, shortlisted submissions will be sent out for blind peer review. We, therefore, encourage students to avoid mentioning their names/affiliations anywhere in their essays. Please note that all submissions will be put through our standard plagiarism detection process.

The top three entries will be published on TP News.

Submissions must be emailed to us as Microsoft Word documents by 11:59 pm UTC on November 7, 2023. We expect to receive a high number of entries and would be unable to respond individually.

Winners will be announced on our website and social media handles in January 2024.

For questions or clarifications, please contact: editor@transferpricingnews.com

NFTC urges Canada to reconsider digital services tax

Canada’s decision to levy a digital services tax despite OECD’s moratorium is shortsighted, Anne Gordon, Vice President for International Tax Policy, National Foreign Trade Council, has said.Continue Reading

Canada publishes draft Global Minimum Tax Act, DST bill

Canada’s government is seeking public input on draft tax legislation to implement a global minimum corporate tax rate, commonly known as GloBE, approved by the OECD’s Inclusive Framework.

Canada’s government is seeking public input on draft tax legislation to implement a global minimum corporate tax rate, commonly known as GloBE, approved by the OECD’s Inclusive Framework.Continue Reading

Tax leaders preparing for Pillar Two impact

A vast majority of tax leaders from multinational enterprises (MNEs) are preparing for the impact of international tax changes resulting from OECD’s Pillar Two project, Deloitte’s 2023 Global Tax Policy Survey has revealed.Continue Reading

Biden Administration rebuked over global minimum tax plans

Members of the Ways and Means Committee, the chief tax-writing committee of the US House of Representatives, have expressed deep concerns about the Biden Administration’s ongoing negotiations with the OECD on the global minimum tax.Continue Reading

OECD cannot decide US international tax policy: Columbia law professor

International tax policy of the United States should be set by the United States, not by other countries, David Schizer, Dean Emeritus, Columbia Law School, has said.Continue Reading

Don’t impose digital services tax: US Chambers to Canada

The US Chamber of Commerce has urged the Canadian government to refrain from unilaterally imposing a digital services tax pending international agreement.Continue Reading

Jenny Austin named chair of ABA’s Transfer Pricing Committee

Jenny Austin has been named chair of the American Bar Association’s (ABA’s) Transfer Pricing Committee.

According to ABA, the Committee aims to establish itself as the “most important forum for global transfer pricing issues.” It will provide advice to members as well as US and foreign government agencies that administer transfer pricing rules.

Austin concentrates her practice on federal tax controversy and litigation, working across all industries, including medical device, pharmaceutical, health care, retail, and technology companies. Her tax controversy experience spans a diverse array of subject matter areas: transfer pricing, cross-border acquisition issues, debt-equity issues, settlement agreements, withholding, privileges, summons enforcement, and penalties. She also has experience with transfer pricing issues at the state level.

Brazil consulting on new transfer pricing tax regulations

Brazil’s Special Secretariat of the Federal Revenue is consulting stakeholders on a draft Normative Instruction that would regulate the country’s new transfer pricing regime.Continue Reading

In Obama’s blacklist once, but leading fight against tax avoidance today: Dutch tax official

Netherlands may have been on Obama’s blacklist in 2009, but it now leads the fight against tax avoidance, Marnix van Rij, Dutch State Secretary for Tax Affairs has said.Continue Reading

Transfer Pricing Reform in Brazil and ‘Options Realistically Available’: New Tax Disputes Ahead?

Law No. 14596/2023 introduced new transfer pricing rules in the Brazilian tax system, in line with the arm’s length standard. The transfer pricing reform is a result of a long project carried out by the Brazilian Federal Revenue Office since 2018, with support from the Organization for Economic Cooperation and Development (OECD) and the United Kingdom (UK), aiming at convergence of Brazil’s transfer pricing rules and the OECD Transfer Pricing Guidelines.Continue Reading

OECD publishes guidance on global minimum corporate tax rules

OECD publishes guidance on global minimum corporate tax rules

The OECD, on February 2, released technical guidance to assist governments with implementation of the 15 percent global minimum corporate tax rate.Continue Reading

Netherlands opposes UN international tax framework

Netherlands warns against UN international tax cooperation framework

The Dutch State Secretary of Finance, Marnix van Rij, has expressed the government’s concerns regarding the recent UN resolution to establish an international tax cooperation framework.Continue Reading

White & Case adds Carlos Martinez to global tax practice

Law firm White & Case LLP has roped in Carlos Martinez as a partner in the firm’s Global Tax Practice.

Martinez will be based out of Mexico. Martinez joins White & Case from Creel Abogados, S.C.

Martinez has extensive experience providing tax advice to domestic and multinational companies on corporate transactions. He also provides advice on international taxation, transfer pricing and tax litigation.

White & Case partner Sang I. Ji, Global Head of the Tax Practice, said: “Carlos brings a wealth of experience acting as tax counsel on complex, cross-border deals. Further strengthening our tax capabilities in Mexico through Carlos’s arrival will support the continued growth and development of our corporate practice in this key market.”

Biden administration rebuked over Hungary tax treaty termination

Biden administration rebuked over Hungary tax treaty termination

The letter calls upon the Biden administration to withdraw its termination of the tax treaty and promptly consult with Congress on a bipartisan basis to address any concerns with the tax treaty or any other of the United States’ current bilateral tax treaties.Continue Reading

Global minimum tax solution to declining corporate tax rates

Global minimum tax solution to declining corporate tax rates

The data underlines the importance of the two-pillar plan being advanced by over 130 members of the OECD/G20 Inclusive Framework on BEPS to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate.Continue Reading

Global minimum corporate tax protects national sovereignty: Janet Yellen

Global minimum corporate tax protects national sovereignty

Yellen has said that the global minimum corporate tax pairs well with our domestic corporate income tax proposals and has the special virtue of helping level the playing field for US business.Continue Reading

Coca Cola asks US Tax Court to reconsider transfer pricing dispute

The Coca-Cola Company has requested the US Tax Court to reconsider a transfer pricing tax ruling it gave last year in favor of the Internal Revenue Service (IRS).

The tax ruling was given on November 18, 2020. According to Coca-Cola, the US Tax Court’s ruling raises fundamental questions of tax, administrative, and constitutional law warranting further consideration by a full Tax Court.

The facts of the tax dispute are as follows. Upon examination of the company’s 2007-2009 returns, IRS determined that the company’s methodology did not reflect arm’s length principle because it overcompensated the supply points and undercompensated the company for the use of its intellectual property.

The US tax authority reallocated income between the company and the supply points employing a comparable profits method that used the company’s unrelated bottlers as comparable parties. These adjustments increased the companys aggregate taxable income for 2007-2009 by more than USD 9 billion.

In its decision, the Tax Court said that the IRS did not abuse its discretion by reallocating income to the company by employing a comparable profits method that used the supply points as the tested parties and the bottlers as the uncontrolled comparables. The US Tax Court further held that the tax authority did not err by re-computing the company’s losses after the comparable profits method changed the income allocable to the company’s Mexican supply point, a branch of the company.

In a Motion for Reconsideration of findings or opinion filed on June 2,  the company said that “the IRS is attempting to impose billions of dollars in additional taxes on Coca-Cola in this case under a different tax calculation method than that on which Coca-Cola justifiably relied and which the IRS audited and approved for over a decade before retroactively requiring Coca-Cola to use a new and different method for tax years long past.  The IRS’s attempt is arbitrary, capricious, and unconstitutional.”

The company added that the US Tax Court has the opportunity to correct these fundamental errors now, and with the utmost respect, Coca-Cola asks the Court to reexamine its opinion in this nationally important, precedential tax case.

The US Tax Court enjoys substantial discretion to reconsider findings of fact and conclusions of law under Tax Court Rule 161, the company said.


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 at editor@transferpricingnews.com

US tax committee investigating AbbVie’s tax practices

AbbVie building and sign in front of a blue sky.

The letter states that AbbVie appears to have shifted profits offshore while reporting a domestic loss in the United States to avoid paying US corporate income tax. The Committee has asked the company to provide answers to specific tax questions no later than June 16, 2021.Continue Reading

Joe Biden’s Budget includes key international tax measures

Joe Biden’s Budget includes key international tax measure

The Budget proposes to increase the income tax rate for C corporations from the existing rate of 21 percent to 28 percent. The proposal would be effective for taxable years beginning after December 31, 2021. Continue Reading

US Senator raises questions about Treasury’s international tax strategy

US Senator raise questions about Treasury’s international tax strategy

The letter states that “there is bipartisan consensus for ensuring that every country plays by the same rules, including China – as President Joe Biden recently said.  No OECD agreement should provide carve-outs or exceptions for our biggest foreign competitors, including China.”Continue Reading

US, Europe discuss digital economy taxation

US, Europe discuss digital economy taxation

Janet Yellen, who took oath as the 78th Secretary of the US Department of the Treasury on January 26, held a discussion with counterparts in France, Germany and the UK on digital economy taxation.Continue Reading

Outline and Considerations for the Pillar One Blueprint Proposals for Amount A

Outline and Considerations for the Pillar One Blueprint Proposals for Amount A

By Simon Webber (Managing Director, Duff & Phelps LLC, New York) & Ryan Lange (Director, Duff & Phelps LLC, New York)

On October 12, 2020 the OECD/G20 Inclusive Framework (IF) released the Report on Pillar One Blueprint. This is a working document that presents the IF’s current thinking on the scope and application of changes to the international tax system to address the Tax Challenges Arising from Digitalization.  Specifically, the OECD is seeking broader consensus and approval for its proposals before moving forward further into a more detailed design.Continue Reading

Digital services taxes of Austria, Spain and UK discriminatory: United States

Digital services taxes of Austria, Spain and UK discriminatory

In a release issued on January 14, the USTR said that the each one of these digital services taxes discriminates against US companies, is inconsistent with prevailing principles of international taxation, and burden or restricts US commerce.Continue Reading

US suspends retaliatory tariffs on French digital services tax

US suspends retaliatory tariffs on French digital services tax

The US Trade Representative said that it has decided to suspend the tariffs in light of the ongoing investigation of similar DSTs adopted or under consideration in ten other jurisdictions.Continue Reading

Indian, Italian and Turkish digital service tax discriminatory: US Trade Representative

Indian, Italian and Turkish digital services tax discriminatory

US Trade Representative has published findings on digital service tax in India, Italy, and Turkey calling it discriminatory and burdensome.Continue Reading

Brian Untermeyer joins Andersen’s international tax practice

Tax firm Andersen has hired Brian Untermeyer as a Managing Director in the firm’s Dallas office.

Untermeyer will join the firm’s international tax practice while serving in a key national role within the US National Tax practice. Untermeyer comes to the firm with more than 30 years of experience in advising inbound and outbound multinational public and private companies on US domestic and international tax issues across multiple industries.Continue Reading

Worst of both worlds: A case against digital services tax in Brazil

Worst of both worlds: strong reasons why the digital services tax should not be implemented in Brazil

By Maurício Barros (Partner at Gaia Silva Gaede Advogados in São Paulo, former Taxpayer-Appointed Judge at the São Paulo Taxes and Fees Court – TIT/SP (2014-2019) and a former Visiting Professor at the Getulio Vargas Foundation and at the Mackenzie Presbiteryan University) & Luiz Guilherme de Medeiros Ferreira (Tax lawyer, São Paulo and Member of the Tax Litigation Commission at the Brazilian Bar Association)

Amid the covid-19 pandemic and the imminent financial crisis of companies, Draft Bill (DB) 2358/2020, drafted by Deputy João Maia, is making its way through the Brazilian Congress. If it becomes law, it will institute a digital services tax (DST) in Brazil, like similar taxes levied in other countries.Continue Reading

US Trade Representative to investigate digital services tax rules in EU, nine others

US Trade Representative to investigate digital services tax rules in EU, nine others

These ten trading partners are: Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the United Kingdom.Continue Reading

Augmenting Loan Documentation in light of Chapter X of the OECD Transfer Pricing Guidelines

Augmenting Loan Documentation in light of Chapter X of the OECD TP Guidelines

By Stefanie Perrella (Managing Director, Duff & Phelps’, New York) and Zachary Held (Director, Duff & Phelps’, New York)

On February 11, 2020, the OECD released its Final Report, Transfer Pricing Guidance on Financial Transactions, (Final Guidance), which was simultaneously incorporated into the OECD Transfer Pricing Guidelines. With respect to inter-company loans, the new Chapter X of the Transfer Pricing Guidelines is not limited to considerations for interest rate pricing, but also includes a framework for assessing the instrument’s accurate delineation as debt. Going forward, taxpayers with lenders or borrowers in OECD countries should consider this new guidance and augment their documentation accordingly. Below are some of the items that these taxpayers should consider to offer a proactive defense of potentially scrutinized areas.Continue Reading

OECD issues MAP peer review reports for further eight jurisdictions

OECD issues MAP peer review reports for further eight jurisdictions

The reports highlight how well these jurisdictions are implementing BEPS Action 14 minimum standard on making tax treaty dispute resolution more timely, effective, and efficient.Continue Reading

US Congresswoman introduces public country by country reporting Bill

US Congresswoman introduces public country by country reporting Bill

The report would include CbC financial filings for the information, including profits, taxes, employees, and tangible assets – that these corporations already provide to the IRS on an annual basis.Continue Reading

OECD issues further guidance on country-by-country reporting

OECD issues further guidance on CbC reporting

The additional interpretative guidance contains complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far.Continue Reading

US responds to French digital tax with USD 2.4 billion tariffs; France calls it ‘unacceptable’

US responds to French digital tax with USD 2.4 billion tariffs; France calls it ‘unacceptable’

French Finance Minister, Bruno Le Maire, termed the US’ proposed action as unacceptable.Continue Reading

Mexican 2020 Tax Reform: key international tax proposals

By Ricardo Rendón (Partner, Chevez, Ruiz, Zamarripa y Cía, S.C., Mexico)

On September 8, 2019, the Executive Branch of the Mexican Government submitted to the Congress Tax Reform for 2020, which includes key tax changes to the country’s tax law primarily inspired by the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading

Manuel Koch joins transfer pricing specialist Questro’s Stuttgart office

Transfer pricing specialist Questro International has hired Manuel Koch as a Partner for the firm’s office in Stuttgart, Germany.

Koch brings significant experience of over ten years specialization in transfer pricing consulting. Koch has wide experience in international tax planning engagements for international corporates including holding and principal structures as well as Swiss finance branches and IP boxes.Continue Reading

Jill Weise to lead Duff & Phelps’ transfer pricing practice

Global advisory firm Duff & Phelps has announced that Jill Weise will succeed Michael Heimert as the Global Leader for the firm’s transfer pricing practice.

Weise has nearly 25 years of expertise in transfer pricing. She previously served as the firm’s transfer pricing practice leader for North America.
  Continue Reading

Indian tax authority sets new CbC reporting deadline for US subsidiaries

Indian tax authority sets new CbC reporting deadline for US subsidiaries

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)


In India, the 2016 Finance Act introduced a three-tiered transfer pricing documentation regime with a view to aligning the Indian transfer pricing documentation rules with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.

Accordingly, Indian subsidiaries of multinational groups were required to comply with new “master” and “local” files requirements and a new country-by-country reporting requirement from the 2016-17 financial year.Continue Reading

Transfer pricing expert Mark Madrian joins Valentiam Group

Transfer pricing expert Mark Madrian has joined Valentiam Group as a Partner in the firm’s West Coast practice.

Madrian has advised clients on complex cross-border transfer pricing and other international tax issues. He was recently recognized as a Leading Transfer Pricing Adviser by Legal Media.
Continue Reading

Cayman Islands publishes tax bill to implement substance requirements

Cayman Islands publishes tax bill to implement substance requirements

The legislation seeks to incorporate the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project, on countering harmful tax practices, as well as the new EU substance requirements.Continue Reading

BDO Melbourne Gets New Tax Partner in Michael Smith

Michael Smith has joined BDO Melbourne’s transfer pricing team as a partner.

Smith has nearly 20 years’ of transfer pricing experience from around the world. He has worked in London, New York, and Sydney.   Continue Reading

Transfer Pricing Regime in Panama: Present and Future

Dealing with cases that have potential transfer pricing implications in Panama requires a high level of expertise in the realm and an extended experience in cases where the common OECD practices are not applicable (Panama is not a member of the OECD).

Panama’s transfer pricing regime constitutes a hybrid insofar as OECD Transfer Pricing Guidelines are concerned. While the OECD Transfer Pricing Guidelines cannot be applied directly, they could be relied upon for interpreting rules provided they are not in conflict with the Panamanian Tax Law. Thus, a transfer pricing study undertaken by one experienced in non-OECD tax jurisdictions – such as www.transferpricing.com.cy – is recommended.Continue Reading

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.
Continue Reading

Google, Facebook to Appear Before EU Tax Committee

Google, Facebook to Appear Before EU Tax Committee
European Parliament’s Special Committee on Tax Avoidance (TAX3) is going to hold a hearing on November 27 with representatives from the Kering Group, Google, and Facebook.
 

The aim of the hearing is to assess the progress made by these multinational enterprises in the implementation of the base erosion and profit shifting project.Continue Reading

Barbados to Align Tax Regime with BEPS Proposals from December 2018

Barbados to Align Tax Regime with BEPS Proposals from December 2019

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 Cabinet has decided to put in place new measures to ensure that the country’s tax regime is compliant with the OECD’s base erosion and profit shifting (BEPS) recommendations, Minister of International Business and Industry, Ronald Toppin, said on November 15.
Continue Reading

OECD Seeks Input on MAP Peer Reviews of Further Eight Jurisdictions

OECD Seeks Input on MAP Peer Reviews of Further Eight Jurisdictions

The OECD is seeking taxpayers’ input for the seventh round of base erosion and profit shifting (BEPS) Action 14 Stage 1 peer reviews of further eight jurisdictions.
Continue Reading

Manal Corwin to Lead KPMG’s Washington National Tax practice

Audit, tax, and advisory firm KPMG LLP has named Manal S. Corwin as the principal-in-charge of the firm’s Washington National Tax practice.

Corwin is based in Washington DC and succeeds Joe Pari. Corwin has served the firm for over five years as national leader of the firm’s International Tax practice and principal-in-charge of international tax policy.Continue Reading

Curtis Best Joins Andersen Tax as Managing Director

Curtis Best has joined the New York office of Andersen Tax as Managing Director. 

Curtis has over 26 years of experience in several areas, including international tax structuring. Best will be a part of the firm’s Commercial Practice group, with a particular focus in international services.Continue Reading

Former US Committee on Ways and Means Tax Counsel Joins Miller & Chevalier

Loren Ponds has joined US law firm Miller & Chevalier as a Member in the firm’s tax department.

Previously, Ponds served as Tax Counsel to the US House of Representatives Committee on Ways and Means, where she was instrumental in the development of the international tax provisions included in the Tax Cuts and Jobs Act of 2017.Continue Reading

Global Solution Needed to Tax Digital Economy: Policy Paper

Global Solution Needed to Tax Digital Economy: Policy Paper

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 US-based Association of International Certified Professional Accountants has called for international coordination to develop a global solution to the tax challenges posed by the digital economy.Continue Reading

EU Digital Services Tax Proposal ‘Unfair’: US Treasury Secretary

EU Digital Services Tax Proposal ‘Unfair’: US Treasury Secretary

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). 


US Treasury Secretary Steven Mnuchin has issued a statement noting “strong” concerns with countries’ consideration of a digital services tax proposal.

In March 2018, the EU Commission announced it proposal to introduce an interim tax, which would cover the main digital activities that currently escape tax altogether in the EU.Continue Reading

Tax Officials Discuss BEPS Implementation Challenges

Tax Officials Discuss BEPS Implementation Challenges

Senior tax experts met at an event in Portugal on October 23 to discuss the strategic importance of the OECD’s work on base erosion and profit shifting (BEPS) and the challenges faced by tax administrations in implementing the BEPS proposals.Continue Reading

Abandon Digital Services Tax Proposal: US Tells EU

Abandon Digital Services Tax Proposal: US Tells EU

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 US Senate Committee on Finance has asked the European Commission to “abandon” its proposal to introduce a three percent digital services tax on revenues arising from the supply of certain digital services.Continue Reading

Further Three Jurisdictions Join BEPS Inclusive Framework

Further Three Jurisdictions Join BEPS Inclusive Framework

Antigua and Barbuda, Dominica, and Saint Vincent and the Grenadines have newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).

The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading

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

No Sweet Tax Deal between Luxembourg, McDonald’s: EU Commission

No Sweet Tax Deal between Luxembourg, McDonald’s: EU Commission

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 EU Commission on September 19 decided that Luxembourg’s tax treatment of McDonald’s Europe Franchising does not violate the Luxembourg-US tax treaty and that tax rulings granted to McDonald’s do not infringe EU State aid rules.

The decision follows an in-depth investigation launched in December 2015, based on doubts that Luxembourg might have misapplied its tax treaty with the US.Continue Reading

Charles Rettig Confirmed as US IRS Commissioner

The US Senate has, by a 64 – 33 vote, confirmed Charles Rettig to be the new Internal Revenue Service (IRS) Commissioner.

During his more than 35 years of professional career with Hochman, Salkin, Rettig, Toscher & Perez, PC, Rettig represented numerous taxpayers before every administrative level of the IRS as well as in matters before the Tax Division of the US Department of Justice, and various other tax authorities.Continue Reading

Former OECD Transfer Pricing Head Joins Squire Patton Boggs

Former OECD Head of Transfer Pricing, Jefferson P. VanderWolk, has joined international law firm Squire Patton Boggs as a partner in the Tax Strategy & Benefits Practice. VanderWolk will work from the firm’s Washington DC office.Continue Reading

Transfer Pricing Aspects of Financial Transactions: Read TEI’s Comments

Transfer Pricing Aspects of Financial Transactions: Read TEI’s Comments

The Tax Executives Institute has responded to the OECD’s public discussion draft on the transfer pricing aspects of financial transactions.

The discussion draft deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.Continue Reading

Transfer Pricing Adjustment Rules Amended in Mexico

Transfer pricing adjustment rules amended in Mexico

By Ricardo Rendón (Partner, Chevez, Ruiz, Zamarripa y Cía, S.C., Mexico)

The Mexican tax authorities last month issued the Second Resolution of modifications to the 2018 Miscellaneous Tax Resolution (MTR) in which the rules regarding transfer pricing adjustments were amended and certain additional provisions were included. This article discusses the relevant modifications to the miscellaneous tax rules on transfer pricing adjustments.Continue Reading

Country by Country Reporting Guidance Updated in Bermuda

Country by Country Reporting Guidance Updated in Bermuda

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 Government of Bermuda has issued an updated tax guidance to assist businesses on complying with Bermuda’s country-by-country (CbC) reporting requirement.Continue Reading

US Transfer Pricing Examination Process: A Critique

US TP Examination Process: A Critique

By Ross B. Newman (CEO and Chief Economist with Altus Economics and Chairman of the Altus Transfer Pricing Network) 

The US Internal Revenue Service (IRS) on June 29 issued the Transfer Pricing Examination Process (TPEP), which replaces the 2014 Transfer Pricing Audit Roadmap (Roadmap) and provides a guide to best practices and processes involved in the three phases of a transfer pricing examination: planning, execution, and resolution.

Continue Reading

New Mexican Transfer Pricing Adjustment Regulations Explained

New Mexican TP Adjustment Regulations Explained

By Guillermo Villaseñor-Tadeo (Partner, Sánchez Devanny, Mexico) and Pedro Palma-Cruz (Attorney, Sánchez Devanny, Mexico)

Mexico’s Tax Administration Service on July 11, 2018, updated the country’s existing regulations concerning transfer pricing adjustments as set out in rules 3.9.1.1 to 3.9.1.5 of the Resolución Miscelánea Fiscal. The changes are aimed at clarifying many questions that arose from the enactment of the first set of regulations on transfer pricing adjustments last year. In broad terms, the regulations can be classified as: definition and types, application, requirements, and timing issues and deadlines. These are discussed below.Continue Reading

Altera and the Arm’s Length Standard

Altera and the Arm’s Length Standard

By Reuven Avi-Yonah (Irwin I. Cohn Professor of Law, University of Michigan)

On July 24, 2018, the Ninth Circuit Court of Appeals reversed the US Tax Court decision in Altera Corp. v. Commissioner, 145 T.C. 91 (July 27, 2015), which had invalidated Treas. Reg. § 1.482- 7A(d)(2).[1]Continue Reading

MNE Tax Avoidance Thing of the Past, OECD Tells G-20

MNE Tax Avoidance Thing of the Past, OECD Tells G-20

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). 


Multinational enterprises (MNEs) are “changing their behavior” as a direct result of recent tax measures taken to tackle base erosion and profit shifting (BEPS), the OECD has told the Group of Twenty (G-20) Finance Ministers.Continue Reading

OECD Briefs G-20 on BEPS Implementation

BEPS Project Already Having an Impact: OECD Tells G-20

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 progress report setting out the major tax developments that took place in the last year concerning the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading

Baker McKenzie Elects New Tax Partners

Law firm Baker McKenzie has announced the election of 13 new tax partners.

The newly elected partners are: Michael Nixon (Singapore), Simone Bridges (Sydney), Kirill Vikulov (Moscow), David Jamieson (London), Jessica Eden (London), Rodrigo Castillo Cottin (Bogota), Paul F. DePasquale (New York), Tatyana Johnson (New York), Victor Alejandro Morales-Chavez (Mexico City), Jonathan Welbel (Chicago), Joshua Nixt (New York), Andrew C. O’Brien-Penney (Chicago), and Ivan Tsios (Chicago).Continue Reading

WZ Advogados Gets New Tax Partner in Artur Braga

Artur Braga has joined São Paulo firm WZ Advogados as a Tax Partner.

Braga joined WZ Advogados after a 20-year career at Ernst and Young (EY). Braga specializes in advising clients in cross-border tax planning, tax litigation, audit reviews, mergers and acquisitions, and corporate restructurings.Continue Reading

US Tax Authority Issues Final Inversion Regulations

US Tax Authority Issues Final Inversion Regulations

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 US Internal Revenue Service (IRS) has issued final regulations on inversions and related transactions.

The final regulations – issued on July 12 – address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code and certain post-inversion tax avoidance transactions.Continue Reading

How Will Brazil’s OECD Membership Affect Its Transfer Pricing Regime?

How Will Brazil’s OECD Membership Affect Its Transfer Pricing Regime?

By Debora De Souza Correa Talutto (Group Transfer Pricing Manager, Temenos Banking Software Co.)

The Brazilian transfer pricing rules were created to address the maximum tax deductible costs or expenses when domestic taxpayers buy goods and services from foreign suppliers, and the minimum taxable revenues when local companies sell goods and services to foreign customers.Continue Reading

Brazil to Revisit Transfer Pricing Regime

Brazil to Revisit Transfer Pricing Regime

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 is working with Brazil to examine the similarities and gaps between the Brazilian and OECD approaches to valuing related-party, cross-border transactions for tax purposes.Continue Reading

US Tax Authority Increases APA User Fees

The US Internal Revenue Service (IRS) has increased user fees for advance pricing agreement (APA) requests filed from July 1, 2018, with a further increase from January 1, 2019.

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 US Internal Revenue Service (IRS) has increased user fees for advance pricing agreement (APA) requests filed from July 1, 2018, with a further increase from January 1, 2019.Continue Reading

Bermuda Updates CbC Reportable Tax Jurisdictions List

Bermuda CbC Reporting Tax Jurisdictions

On January 31, 2018, Bermuda’s Finance Ministry released an updated list of tax jurisdictions that will be treated as “reportable jurisdictions” for the purposes of the country-by-country (CbC) reporting standard for the 2016 and 2017 reporting periods.Continue Reading

Google Happy to Pay More Taxes: Sundar Pichai

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). 


Google is happy to pay a higher amount of tax, Sundar Pichai, chief executive officer of Google Inc, has said.Continue Reading

UK, US, Six Others Launch Multilateral Tax Risk Assurance Program For MNEs

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). 


Eight tax administrations, including the UK and the US, have launched a pilot program for the multilateral risk assessment of multinational corporations.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

US IRS Issues Five New Transfer Pricing Directives

US Internal Revenue Service publishes tax directives on key transfer pricing matters

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). 


On January 16, 2018, the US Internal Revenue Service published five new tax directives, which provide instructions to Large Business & International (LB&I) examiners on key transfer pricing matters.Continue Reading

Indian IT Giant Infosys Signs APA with US

TP News India Tax

Indian IT giant Infosys Limited has announced the successful conclusion of an advance pricing agreement (APA) with the US Internal Revenue Service (IRS), a move that will enhance predictability of the company’s tax obligations in respect of its US operations.Continue Reading