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.
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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.
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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.
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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 Transfer Pricing 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.

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New Mexican Transfer Pricing Adjustment Regulations Explained

New Mexican Transfer Pricing 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