Global advisory firm Duff & Phelps has hired Ted Keen, who will serve as the European leader for the firm’s transfer pricing practice from London.
The Swiss Federal Tax Administration (FTA) will exchange this month 109 country-by-country (CbC) reports of multinational enterprises’ (MNEs) with 35 foreign tax jurisdictions.
The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD to counter tax base erosion is dim long over-due. Indeed, the case with transfer pricing is technically considered a neutral concept but erroneously taken as an offensive action of MNEs that permits them to transfer profits generated by intangibles to so-called tax havens. Although, the arm’s length principle enshrine in the OECD Model has been misidentified as the primary instrument to tackle such abusive behavior of MNEs.
When states attain membership of the European Union (EU), the governments are in charge of enacting and implementing their local direct taxation policy. The tax framework of the member-states shall not contravene or interfere the laid down policies and directives of the EU institutions; therefore, the sovereignty of member states is extremely safeguarded. Although the EU faces difficulties to come up with results that would be generally accepted by all member states, it has taken every step to integrate all Member States’ corporate direct taxation systems since the 1950s.
The OECD has released additional guidance on the attribution of profits to permanent establishment (PE), as part of its work on base erosion and profit shifting (BEPS) Action 7.
The OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS) will enter into force on July 1, 2018.
The OECD on March 16 released its Interim Report on the Tax Challenges Arising from Digitalisation, noting a lack of consensus among countries on either the merit or the need for interim measures to address the tax challenges posed by the digital economy.
On March 12, 2018, the OECD published mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain.
In a first, the European Commission has stressed that tax rules in seven EU member states facilitate corporate tax avoidance by multinational enterprises (MNEs).
Austria’s leading tax lawyer, Franz Althuber, has left DLA Piper to start his own firm, Althuber Spornberger & Partners.