Singapore to implement Pillar 2 tax rules from 2025

Singapore to implement Pillar 2 tax rules from 2025

Singapore will implement the Global Anti-Base Erosion (GloBE) Rules, that is, Income Inclusion Rule and Undertaxed Profits Rule, and Domestic Top-up Tax from January 1, 2025.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

OECD releases key documents on two-pillar international tax reform

International tax reform to yield significant revenue: OECD

The OECD, today, released key documents as part of its two-pillar solution to reform international tax rules to address the tax challenges arising from globalization and digitalization.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

EU Commissioner underlines corporate tax reform plan

A global minimum corporate tax rate and the reallocation of taxing rights between jurisdictions must be implemented in due time to provide a fairer and more stable global corporate tax system, Paolo Gentiloni, European Commissioner for Economy, has said.

A global minimum corporate tax rate and the reallocation of taxing rights between jurisdictions must be implemented in due time to provide a fairer and more stable global corporate tax system, Paolo Gentiloni, European Commissioner for Economy, has said.Continue Reading

Malta gazettes transfer pricing rules

Malta gazetted transfer pricing rules

On November 18, 2022, Malta gazetted Transfer Pricing Rules, 2022.

As per the rules, in ascertaining the total income of any company:

  • where any amount incurred or due, in the year preceding the year of assessment under any cross-border arrangement to which the transfer pricing rules apply, differs from the arm’s length amount, it shall be deemed that the arm’s length amount was incurred or due as opposed to the actual amount incurred or due; and
  • where any amount accrued or derived, in the year preceding the year of assessment under any cross-border arrangement to which the transfer pricing rules apply, differs from the arm’s length amount, it shall be deemed that the arm’s length amount was accrued or derived instead of the actual amount accrued or derived.

Continue Reading

Spain, Ireland fastest in closing MAP cases under tax treaties

Spain has been awarded for taking the shortest time in closing transfer pricing cases under the mutual agreement procedure (MAP) set out in tax treaties.

The 2021 MAP Statistics were presented during the OECD Tax Certainty Day, where tax officials and stakeholders took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution. The MAP Award is given in recognition of efforts by competent authorities in dealing with MAP cases.Continue Reading

Swiss tax administration appoints next Director

The Swiss Federal Council has appointed Tamara Pfammatter as the new Director of the Federal Tax Administration (FTA) with effect from April 1, 2023.

Pfammatter, who will succeed Adrian Hug, is currently an ambassador and a member of management at the State Secretariat for International Finance (SIF). As the Head of the Tax Division, she is responsible for Switzerland’s international tax dossiers and for the multilateral negotiations in the OECD’s project on taxing the global economy.

For over a year prior to her current post, she was deputy divisional head in the Tax Division and divisional head in the Corporate Taxation Policy Division at SIF. From 2009 to 2020, she worked as a project leader in the Tax Policy Division of the FTA. 

Australia expanding tax treaty network

Australia expanding tax treaty network

The Australian government is expanding its tax treaty network to provide improved certainty to taxpayers and guard against tax avoidance practices.

New negotiations are planned with Bulgaria, Colombia, Croatia, Cyprus, Estonia, Latvia, and Lithuania. These countries add to the current program which includes Portugal, Slovenia, Greece, and Luxembourg.Continue Reading

Luxembourg transfer pricing ruling did not favour Fiat: EU top court

Luxembourg transfer pricing ruling did not favour Fiat: EU top court

The Court of Justice of the European Commission annuls the European Commission’s 2015 finding that Luxembourg granted selective tax advantages to Fiat through a transfer pricing ruling, in breach of EU state aid rules.Continue Reading

EU Commission extends inquiry into Gibraltar’s corporate tax regime

EU Commission extend inquiry into Gibraltar’s corporate tax regime

The Commission has decided to extend the scope of its original investigation to specify further the measure in favour of MJN GibCo, in line with the Court’s indications, and reassess the information submitted by the UK in relation to MJN GibCo 2012 tax ruling.Continue Reading

UK releases draft rules on global minimum tax

UK government, on July 20, released draft rules aimed at ensuring multinational enterprises (MNEs) operating within the UK pay a global minimum level of tax.

The draft rules are in line with the agreement on a 2 Pillar solution to reform the international tax framework made by the G20 — Organisation for Economic Co-operation and Development Inclusive Framework on Base Erosion and Profit Shifting (BEPS) last year.Continue Reading

Implemented modifications to the German Transfer Pricing Legislation

By Dr. Björn Heidecke (Director, Transfer Pricing, Deloitte, Germany) & Neeraj-Kumar Popat (Senior Manager, Transfer Pricing Deloitte, Germany)

On June 8, 2021 Germany implemented modifications to the Transfer Pricing Legislation in both the Foreign Tax Act (Außensteuergesetz) and the Fiscal Code (Abgabenordnung). Most of the modifications were already proposed with a previous initiative in March 2020 (for further information see Link: Proposed modifications to the German Transfer Pricing Legislation), however, this initiative was excluded from the final legislation passing process. In a subsequent initiative, most of the modifications from the previous initiative were included and proposed in January 2021. This proposal was now finally implemented in June 2021.Continue Reading

EU Council adopts position on public country by country reporting of tax info

EU Council adopt position on public country by country reporting of tax

The reporting will take place within 12 months of the date of the balance sheet for the financial year in question. The directive sets out the conditions under which a company may defer the disclosure of certain information for a maximum of five years. Continue Reading

Anguilla, Dominica, and Seychelles removed from EU tax blacklist

Anguilla, Dominica, and Seychelles removed from EU tax blacklist

Anguilla, Dominica, and Seychelles are now included in the state of play document (Annex II), which covers jurisdictions that do not yet comply with all international tax standards but that have committed to implementing tax good governance principles.Continue Reading

European Commission hails G20 agreement on digital tax

European Commission hails G20 agreement on digital tax

The tax reform package will include a reallocation of taxing rights – where companies pay tax wherever they conduct business – and a global minimum effective tax rate of at least 15 percent to tackle aggressive tax planning and stop the corporate tax “race to the bottom.” Continue Reading

EU Commission asks Bulgaria, Sweden to address tax issues

Under this tax scheme, interest deductibility is denied in relation to loan arrangements between affiliated companies established within the EU, irrespective of whether the terms and conditions of those arrangements remain at arm’s length or not.Continue Reading

Tax administrations discuss transfer pricing issues

The WCO facilitator focused on the Customs valuation treatment of related-party transactions and instruments adopted by the Technical Committee on Customs Valuation. The OECD facilitator elaborated on the arm’s length principle and its application, comparability analysis, and transfer pricing documentation.  Continue Reading

International tax reform takes center stage in G7 meeting

The G7 (which includes the UK, the US, Canada, Japan, Germany, France, Italy, plus the EU) agreed the principles of an ambitious two Pillar global solution to tackle the tax challenges arising from an increasingly globalized and digital global economy.Continue Reading

Cyprus extends DAC6 penalty relief

Cyprus extends DAC6 penalty relief

On March 18, 2021, the Government approved Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

Cyprus extend DAC6 penalty relief

The Cyprus Tax Department will not impose administrative fines for overdue submission of DAC6 information that will be submitted until the September 30, 2021.

The penalty relief applies to:

  • Reportable cross-border arrangements that have been made between 25 June 2018 and 30 June 2020 and had to be submitted by 28 February 2021.
  • Reportable cross-border arrangements that had been made between 1 July 2020 and 31 December 2020 and had to be submitted by 31 January 2021.
  • Reportable cross-border arrangements made between 1 January 2021 and 31 August 2021, that had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation has been made, whichever occurred first.
  • Reportable cross-border arrangements for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 31 August 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance or advice.

On March 18, 2021, the Government approved Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

Stakeholders engage on changes to OECD Model Tax Convention

The OECD has received comments from 22 stakeholders including the Big 4, Mexican Institute of Public Accountants, International Chamber of Commerce, European Business Initiative on Taxation, Business at OECD (BIAC), and Vienna University of Economics and Business, among others.Continue Reading

EU governments agree on MNE tax reporting

EU governments agree on MNE tax reporting

The reporting will take place within 12 months from the date of the balance sheet of the financial year in question. The directive sets out the conditions under which a company may obtain the deferral of the disclosure of certain elements for a maximum of five years.Continue Reading

EU Commission launches research lab to tackle aggressive tax planning

EU Commission launches research lab to tackle tax planning

The Observatory will be fully independent in conducting its research, objectively informing policymakers and suggesting initiatives that could help to better tackle tax avoidance and aggressive tax planning, among other things.Continue Reading

Hungary dismisses 15% global minimum corporate tax rate

Hungary dismisses 15% global minimum corporate tax rate

Tállai emphasized that Hungary would not relinquish one of the most important elements of its economic sovereignty, the right to set taxes. According to him, the idea of a global minimum tax is in the interests of several high-taxing economic powers, because they were disadvantaged by international tax competition.Continue Reading

“The controlled transaction” in draft of the Poland’s Ministry of Finance General Ruling for Transfer Pricing Purposes

BKuzniacki_PWC Poland

By Błażej Kuźniacki (Attorney-at-Law, Deputy Director for Strategic Tax Advice & Dispute Resolution,PwC Poland) & Katarzyna Kotowska (Senior Associate, Transfer Pricing, PwC Poland) & Piotr Niewiadomski (Tax Advisor, Director in Transfer Pricing, PwC Poland)

The definition of controlled transaction in the light of Polish Corporate Income Tax Act (CIT Act) and explanatory memorandum

According to Article 11a point 6 of the CIT Act, a controlled transaction refers to economic activity identified on the basis of actual behavior of the parties to the transaction, including allocation of income to the foreign permanent establishment (PE), where the conditions are imposed/made as a result of existing relations.Continue Reading

Parties to BEPS MLI approve key guiding principles

Parties to BEPS MLI approves key guiding principles

The Conference has agreed that as with any international agreement, the MLI shall be interpreted in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in the light of its object and purpose.Continue Reading

Paschal Donohoe discusses international tax reform

Paschal Donohoe discusses international tax reform

Donohoe said that he desired “an outcome that is a fair and balanced compromise by and for all the 139 countries in the OECD Inclusive Framework.”

Paschal Donohoe discussion on international tax reform

Ireland’s commitment remains resolute towards reaching an agreement on digital economy taxation, Ireland’s Minister for Finance, Paschal Donohoe, has said.Continue Reading

Ireland consulting on tax treaty policy

Ireland consulting on tax treaty policy

The consultation period will run until May 7, 2021.

Ireland consultation on tax treaty policyIreland’s Finance Minister on April 7 launched a public consultation on Ireland’s future tax treaty policy, particularly in the context of potential outcomes of international tax discussions at the OECD.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

Ireland updates corporate tax roadmap

According to the update, Ireland will seek to implement interest limitation rules in accordance with the Anti-Tax Avoidance Directive (ATAD) standard; legislate for new international tax transparency rules for digital platforms; legislate for reverse hybrids aspect of ATAD anti-hybrid rules; adopt the authorized OECD approach for transfer pricing of branches; and consider actions that may be needed in respect of outbound payments from Ireland and our wider withholding tax regime.Continue Reading

Platform for Collaboration on Tax releases toolkit on transfer pricing documentation

Platform for Collaboration on Tax releases toolkit on transfer pricing documentation

The toolkit aims to help countries implement effective transfer pricing documentation requirements so that they can protect their tax bases, reduce profit shifting, and raise much-needed revenues for the recovery phase.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

Portuguese EU Presidency to focus on digital economy taxation

Portuguese Presidency of the Council of the European Union

In particular, the Presidency will address the challenges of European taxation, including the model for taxation of the digital economy, under the principles of fairness and tax efficiency.Continue Reading

OECD releases agenda for public consultation on Pillar One, Pillar Two Reports

The Blueprints reflect the convergent views of the Inclusive Framework on many of the key policy features, principles and parameters of both Pillars, and identify remaining technical and administrative issues as well as policy issues where divergent views among Inclusive Framework members remain to be bridged.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

UK to repeal DAC6 in 2021

The UK tax authority, HM Revenue and Customs, has announced that it will repeal the DAC6 reporting requirement in 2021 and replace it with the OECD’s mandatory disclosure rules (MDR).

The announcement was made after completion of the negotiations between the UK and the EU on a Free Trade Agreement (FTA).

In a letter sent to stakeholders on December 31, HMRC said that reporting under DAC6 will still be required for a limited time, but only for arrangements which meet hallmarks under Category D, in line with the UK’s obligations under the FTA.

Category D sets out specific hallmarks concerning automatic exchange of information and beneficial ownership.

The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2) (EU Exit) Regulations, 2020 – laid before the House of Commons on December 30 – state that “(5) For the purposes of these Regulations, the DAC is to be read as if— (h) in Annex IV, Part 1 [the Main Benefit Test] and hallmark categories A, B, C and E in Part II were omitted.”

In the coming year, the UK will consult on and implement the OECD’s MDR as soon as practicable, to replace DAC6 and transition from European to international rules, HMRC told stakeholders.

OECD issues guidance on transfer pricing implications of COVID-19 pandemic

OECD issues guidance on transfer pricing implications of COVID-19 pandemic

The guidance on transfer pricing implications of the COVID-19 pandemic represents the consensus view of the 137 members of the OECD Inclusive Framework on BEPS.Continue Reading

Germany, Pakistan ratify BEPS MLI to tackle tax avoidance

Germany, Pakistan ratifies BEPS MLI to tackle tax avoidance

Germany and Pakistan have deposited their instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).Continue Reading

OECD reveals country practices on hard-to-value intangibles

OECD reveals country practices on hard-to-value intangible

The information provides with a better understanding of the extent to which the HTVI approach described in Chapter VI of the Transfer Pricing Guidelines has been adopted and is applied in practice by countries around the world. Continue Reading

MAP cases still taking a long time to be resolved: OECD

MAP cases taking a long time to be resolved

Around 85 percent of the MAPs concluded for transfer pricing cases in 2019 fully resolved the issue, which reflects an improvement in the collaborative approach taken by competent authorities.Continue Reading

Proposed modifications to the German Transfer Pricing Legislation

Dr. Björn Heidecke (Partner,  Deloitte Germany, Hamburg)

By Dr. Björn Heidecke (Director, Deloitte Germany, Hamburg) & Tatchamon Nanavaratorn (Senior Consultant, Deloitte Germany, Hamburg)

As part of the obligation to implement the European-wide mechanism to counter base erosion and profit shifting, the German Federal Ministry of Finance circulated a draft law on 10 December 2019 (hereafter referred to as “draft law”). Besides conforming to the requirement as directed by the EU Anti-Tax Avoidance Directive, the draft law brings about the modification to the current transfer pricing legislation of both the Foreign Tax Act (Außensteuergesetz) and the Fiscal Code (Abgabenordnung), and it introduces topics not previously codified into the legislation in accordance with the BEPS concepts introduced by the OECD. The draft law takes a strict stance on businesses’ actual conducts rather than their contractual arrangements.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

Belgian Transfer Pricing Circular sets out tax authority’s view on 2017 OECD Guidelines

View of Belgian Tax Administration on 2017 OECD Guidelines and specific positions

By Géry Bombeke (Partner, Baker McKenzie, Brussels)

On February 25, 2020, the Belgian Tax Administration published a new transfer pricing Circular (Circular 2020/C/35) (TP Circular) summarizing the post-base erosion and profit shifting (BEPS), OECD Transfer Pricing Guidelines and reflecting the tax authority’s views thereon.Continue Reading

BVI to accept country by country report filings from March 2020

BVI to accept country by country report filings from March 2020

International Tax Authority informs BVI Constituent Entities, that are part of Multinational Entity Group, that it will soon be ready to receive filings for CbC reporting.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

EU Commission warns Austria, Ireland to transpose interest limitation rules

EU Commission warns Austria, Ireland to transpose interest limitation rules

The Commission may bring the cases before the Court of Justice of the EU if Austria and Ireland do not act by February 1, 2020.Continue Reading

Ireland Transfer Pricing Feedback Statement Explained

Ireland's Transfer Pricing Feedback Statement Explained By Expert

By Catherine O’ Meara (Partner, Matheson, Dublin)

The Irish Government recently published a Transfer Pricing Rules Feedback Statement, which confirms that changes to the country’s transfer pricing rules and their implementation are forthcoming.Continue Reading

OECD preparing for ‘big bang’ reform to address digital economy taxation

Gurría also described the delivery of the OECD’s BEPS package in 2015 as one of the two “big bang” developments that transformed the global tax landscape in recent years.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

New EU corporate tax avoidance rules enter into force

New EU corporate tax avoidance rules enter into force

The new anti-abuse measures entered into force on January 1, 2019.Continue Reading

Gibraltar provided illegal tax benefits to MNEs: EU Commission

EU Commission says Gibraltar provided illegal tax benefits to MNEs

Gibraltar must recover unpaid taxes of around EUR100m from companies that benefited from the corporate tax exemption regime for interest and royalties as well as from the five tax rulings.Continue Reading

OECD issues second peer review report on BEPS Action 5

OECD issues second peer review report on BEPS Action 5

The OECD has made 60 jurisdiction-specific recommendations on issues such as improving the timeliness of the exchange of information and ensuring that exchanges of information are made with respect to preferential tax regimes that apply to income from intellectual property.Continue Reading

Bulgaria introduces new interest limitation and CFC regimes

Bulgaria introduces new interest limitation and CFC regimes

By Elizabeth Sidi (Senior Tax Consultant, PwC, Bulgaria) 

Bulgaria is introducing new interest limitation rules and a new controlled foreign corporation regime from January 1, 2019. 

Continue Reading

Indian tax authority undergoing ratification process for BEPS MLI

Indian tax authority undergoing ratification process for BEPS MLI

Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.

Continue Reading

Belgium publishes draft transfer pricing guidance for public comments

Belgium publishes draft transfer pricing guidance for public comments

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The Belgian tax authority has issued a draft Circular on the 2017 update to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.Continue Reading

Netherlands to Deny Tax Rulings to ‘Letterbox’ Companies

Netherlands to Deny Tax Rulings to ‘Letterbox’ Companies

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  


Netherlands will be putting into place stricter requirements for the issue of international tax rulings by the end of June 2019.
Continue Reading

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

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  


Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta.
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

EU Joint Transfer Pricing Forum Issues Recommendations on Multilateral Transfer Pricing Audits

EU Joint Transfer Pricing Forum Issues Recommendations on Multilateral Transfer Pricing Audits

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The EU Joint Transfer Pricing Forum has published a report, which aims to address the lack of guidance on bilateral and multilateral transfer pricing audits.
Continue Reading

Global Solution Needed to Tax Digital Economy: DIGITALEUROPE

Global Solution Needed to Tax Digital Economy: DIGITALEUROPE

DIGITALEUROPE, which represents the digital technology industry in Europe, has called upon governments to negotiate a comprehensive, global, long-term tax solution at the OECD-level to address the tax challenges of the digital economy.
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

Ireland Consulting on Corporate Anti-Tax Avoidance Measures

Ireland Consulting on Corporate Anti-Tax Avoidance Measures

On November 14, 2018, Ireland’s Department of Finance published for public comments a consultation document on the hybrid mismatch and interest limitation measures to be introduced as part of the implementation of the EU Anti-Tax Avoidance Directives (ATAD and ATAD2).
Continue Reading

Transfer Pricing Regulation in Albania and Recent Developments

Transfer Pricing Regulation in Albania and Recent Developments

By Erinda Xhaferraj (Tax Manager, PwC, Albania) and Edland Graci (Transfer Pricing Senior Associate, PwC, Spain)

The amendment in 2014 of Albania’s Income Tax Law and the release of the Transfer Pricing Instruction introduced changes that are of importance to Albanian taxpayers performing cross-border transactions. For the first time taxpayers were faced with a complex and sophisticated legislation, which required the application of arm’s length in intra-group transactions.Continue Reading

OECD Issues Guidance on the Impact of BEPS MLI

OECD Issues Guidance on the Impact of BEPS MLI

The OECD has published new guidance for the development of synthesised texts to facilitate the interpretation and application of tax agreements modified by the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI).Continue Reading

Countries Discuss Implementation of BEPS Minimum Standards

Countries Discuss Implementation of BEPS Minimum Standards

More than 60 delegates from 16 countries met recently at the regional meeting of the Inclusive Framework on base erosion and profit shifting (BEPS) in Eastern Europe and Central Asia to discuss implementation of the BEPS measures.Continue Reading

UK Announces 2% Digital Services Tax From 2020

UK Announces 2% Digital Service Tax From 2020

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). 


UK would introduce a two percent digital services tax (DST) to ensure digital businesses pay tax that reflects the value they derive from UK users, UK Chancellor Philip Hammond announced in his October 29 Budget Speech.Continue Reading

Ukraine Publishes Draft Tax Law to Implement BEPS Proposals

Ukraine Publishes Draft Tax Law to Implement BEPS Proposals

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). 


Ukraine has published a draft law aimed at implementing some of key measures proposed under the OECD’s base erosion and profit shifting (BEPS) project.
Continue Reading

Ireland Signs Order to Ratify BEPS Convention

Ireland Signs Order to Ratify 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). 


Ireland’s Government has signed an Order to facilitate ratification of the OECD’s Multilateral Instrument to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).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

New Japan, Spain Tax Treaty to Include MAP Arbitration

New Japan, Spain Tax Treaty to Include MAP Arbitration

Japan and Spain signed a new tax treaty on October 16. The tax treaty wholly amends the existing tax treaty between Japan and Spain, which entered into force in 1974.

As per the new tax treaty, a withholding tax exemption applies to investment income from interest and royalties. Withholding tax on dividends is also exempt in certain situations.Continue Reading

Switzerland Expands Country List for Exchange of CbC Reports

Switzerland Expands Country List for Exchange of CbC Reports

The Swiss Federal Council on October 17 decided to expand the list of countries with which Switzerland would exchange country-by-country (CbC) reports.

The legal basis for the exchange of CbC reports entered into force for Switzerland on December 1, 2017. Switzerland had then submitted to the OECD a list of 108 countries with which the Government will exchange CbC reports.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

Liberia: Where Transfer Pricing is in Full Bloom

Liberia is a typical example amongst developing African countries making noticeable effort to expand their tax base to the size it should appropriately be, therefore collecting more taxes and adapting to the fast-changing local and global business environment.Continue Reading

Belgium Announces Cooperative Tax Compliance Program

Belgium Announces Cooperative Tax Compliance Program

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The Large Enterprises Division of the Belgian tax administration has announced the launch of a two-year pilot project aimed at transforming the traditional approach of ex-post tax investigations towards a system of proactive, real-time, and constructive dialogue on corporate tax affairs.

Continue Reading

Ireland Finance Bill 2018 to Include International Tax Measures

Ireland Finance Bill 2018 to Include International Tax Measures

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). 


Ireland would introduce key international tax measures in Finance Bill 2018 to comply with the EU Anti-Tax Avoidance Directive, Finance Minister Paschal Donohoe said in his 2019 Budget Statement released on October 9. The Finance Bill 2018 is due to be published on October 18.Continue Reading

Norway’s Budget 2019 Includes BEPS Measures

Norway’s Budget 2019 Includes BEPS Measures

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 Norwegian Government on October 8 presented the country’s National Budget 2019, which includes a series of measures to tackle base erosion and profit shifting (BEPS).Continue Reading

Countries Share Ideas on Country by Country Reporting Implementation

Countries Share Ideas on Country by Country Reporting Implementation

Senior tax officials from over 20 countries recently met at a workshop to share experiences from the first year of country-by-country (CbC) reporting and explore how information can be used most effectively in the tax risk assessment of MNE groups.Continue Reading

Aruba Newest to Join BEPS Inclusive Framework

Aruba Newest to Join BEPS Inclusive Framework

Aruba has now 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

More Countries Ratify BEPS Convention

More Countries Ratify BEPS Convention

Australia, France, Japan, and the Slovak Republic have deposited their instruments of ratification of the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).

For these four countries, the BEPS Convention would enter into force from January 1, 2019. The Convention entered into force last month for New Zealand, Serbia, Sweden, and the UK.Continue Reading

EU Commission to Drop Infringement Proceedings in Ireland-Apple State Aid Decision

EU Commission to Drop Infringement Proceedings in Ireland-Apple State Aid Decision

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 is now to withdraw infringement proceedings against Ireland as the Government has now completed full recovery of the alleged State aid from Apple.Continue Reading

Saudi Arabia Signs OECD’s BEPS Multilateral Instrument

Saudi Arabia Signs OECD’s BEPS Multilateral Instrument

Saudi Arabia has become the 84th tax jurisdiction to sign the base erosion and profit shifting (BEPS) Multilateral Convention.

The BEPS Convention, negotiated by over 100 countries and jurisdictions, updates the existing network of 1,400 bilateral tax treaties and reduces opportunities for tax avoidance by multinational enterprises.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

ICC Welcomes OECD Draft on Transfer Pricing Aspects of Financial Transactions

ICC Welcomes OECD Draft on Transfer Pricing Aspects of Financial Transactions

The International Chamber of Commerce (ICC) has largely welcomed 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

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

BEPS Instrument to Enter into Force in January 2019 for Israel, Lithuania

BEPS Instrument to Enter into Force in January 2019 for Israel, Lithuania

Israel and Lithuania have newly deposited with the OECD their instrument of ratification for the Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) measures.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

Draft Tax Proposal Drastically Expands Scope of Finnish CFC Regime

Draft Tax Proposal Drastically Expands Scope of Finnish CFC Regime

By Mika Ohtonen (Head of Tax, Roschier, Finland) & Laura Puro (Senior Associate, Roschier, Finland)

Finland’s Ministry of Finance last month published a draft proposal on amending the Finnish controlled foreign corporation (CFC) statute. While the purpose of the draft is to implement the CFC provisions of the Anti-Tax Avoidance Directive (ATAD), the proposed changes are materially stricter than required by the ATAD.Continue Reading

Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law

Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law

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). 


Ireland’s Finance Minister Paschal Donohoe has published the country’s Corporation Tax Roadmap outlining the steps that the Government will take in the area of international tax law over the next few years.Continue Reading

Countries Lowering Corporate Income Tax Rates

Countries Lowering Corporate Income Tax Rates

A new OECD report reveals that countries have used recent tax reforms to lower corporate income tax.

Tax Policy Reforms 2018 highlights the continuation of a trend toward corporate income tax rate cuts, which has been largely driven by significant reforms in a number of large countries with traditionally high corporate tax rates.Continue Reading

MAP Peer Review Reports Out for Australia, Ireland, Japan, Five Others

MAP Peer Review Reports Out for Australia, Ireland, Japan, Five Others

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 on August 30 published stage 1 mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal.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

Finland Consulting on Draft Controlled Foreign Corporation Rules

Finland Consulting on Draft Controlled Foreign Corporation Rules

By Sami Tuominen (Partner, Head of Tax, Bird & Bird, Finland) &  Marianna Santamala (Associate, Bird & Bird, Finland)

The Finnish Ministry of Finance recently proposed amendments to the current Finnish legislation concerning controlled foreign corporations (CFC). On August 6, 2018, the Finance Ministry submitted a proposal for Government Bill on the amendments to the Act on taxation of members of controlled foreign companies (Act). The Act is currently going through a consultation round and the Ministry would accept input until the end of this month. The purpose of the Act is to prevent the avoidance of taxation in Finland by utilizing corporations established in states with low taxation.Continue Reading

Transfer Pricing Documentation: Belgium Gazettes Administrative Fines

Transfer Pricing Documentation: Belgium Gazettes Administrative Fines

By Stefaan De Ceulaer (Director, Tax and Legal Support, PKF International)

The Belgian Parliament on June 29 adopted the Programme Act, which introduces in Belgian tax law specific transfer pricing documentation requirements, that is, in article 321/1 to 321/7 of the Income Tax Code (Programme law of July 1, 2016 gazetted on July 4, 2016), in response to Action 13 of the OECD’s base erosion and profit shifting (BEPS project.  Continue Reading

Transfer Pricing Documentation Regime Being Revised in Poland

Transfer Pricing Documentation Regime Being Revised in Poland

By Marcin Jamroży (Associate Professor, Warsaw School of Economics, and Partner, Rödl & Partner, Poland)

Poland’s Finance Ministry recently published a draft tax Bill to implement key changes to the country’s transfer pricing documentation rules. The draft Bill is aimed at simplifying Poland’s transfer pricing regulations and lowering the bureaucratic and administrative burden for enterprises. The philosophy of a simple, transparent, and friendly tax system should be written into the law. At the same time, it is underlined that the draft Bill should be sealed against loopholes and incorporate the new OECD recommendations. The new regulation is proposed to be effective from January 1, 2019.Continue Reading

Spain’s Patent Box Regime Aligned with BEPS Action 5

Spain's Patent Box Regime Aligned with BEPS Action 5

By Mario Ortega Calle (Partner, Garrigues, Madrid) and Laura Jiménez (Associate, Garrigues, Madrid)

Spain’s General State Budget for 2018, published by Law 6/2018 of July 3, 2018, in the Official Gazette, has amended the country’s patent box regime to bring it in further alignment with the “nexus approach” developed by the OECD under Action 5 of the base erosion and profit shifting (BEPS) project.Continue Reading

UK Raises £388 million from Diverted Profits Tax Law in 2017-18

UK Raises £388 million from Diverted Profits Tax Law in 2017-18

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 UK tax authority, HM Revenue and Customs (HMRC), raised GBP388m from the diverted profits tax (DPT) legislation in 2017-18, according to the Transfer Pricing and Diverted Profits Tax Statistics published on July 31.Continue Reading

Franka Sturm Joins Houthoff’s Tax Practice as Counsel

Houthoff, one of the largest law firms in the Netherlands, has hired Franka Sturm as Counsel for the firm’s tax practice.

Sturm has over 13 years of experience as a tax specialist in international practice with a focus on M&A and oil and gas.

Before joining Houthoff, Sturm worked with the Dutch Tax and Customs Administration and with PwC as a Senior Tax Manager.

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

BusinessEurope Calls for Global Agreement on Digital Economy Taxation

BusinessEurope Calls for Global Agreement on Digital Economy Taxation

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 Confederation of European Business (BusinessEurope) has said that a global agreement is needed on changes to international tax rules concerning the digital economy to ensure a global level-playing field encompassing all major tax jurisdictions.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

New Italian Transfer Pricing Guidelines Explained

New Italian Transfer Pricing Guidelines Explained

By Diletta Fuxa (Senior Manager), Studio Associato Servizi Professionali Integrati, Member of Fieldfisher

On May 14, 2018, Italy’s Ministry of Economy and Finance issued a Decree, which lays down new transfer pricing guidelines in compliance with the provisions set forth in article 110 (7) of the Income Tax Code (Testo Unico delle Imposte sui Redditi).Continue Reading

Report on Taxation of Offshore Indirect Transfer of Assets Issued

Report on Taxation of Offshore Indirect Transfer of Assets Issued

The Platform for Collaboration on Tax – a joint initiative of the IMF, the OECD, the UN, and the World Bank Group – has published for public comments a revised version of its report on taxation of offshore indirect transfers of assets.Continue Reading

EU Committee Calls For Fair, Uniform Taxation of Digital Economy

EU Committee Calls For Fair, Uniform Taxation of Digital Economy

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 European Economic and Social Committee (EESC) has called for a fair, consensus-based international solution at the OECD-level to tackle tax challenges posed by the digital economy. 

The EU advisory body said that contrary to common international corporate taxation practice, the European Commission’s proposals aims to tax businesses’ turnover instead of profits, and to levy taxes where sales take place instead of where value is created. This approach, it noted, could jeopardize the integrity of the EU single market and lead to double taxation.Continue Reading

UK to Amend Corporate Interest Restriction Rules

UK to Amend Corporate Interest Restriction Rules

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 UK Government has published draft legislation that would make technical amendments to the country’s corporate interest restriction rules to ensure the corporation tax regime works as intended.Continue Reading

Guernsey Signs New Tax Treaty With UK

Guernsey Signs New Tax Treaty With UK

Guernsey has signed a new tax treaty with the UK. The new tax treaty replaces the one that has been in force since 1951.

The new tax treaty is based, broadly, on the OECD Model Tax Convention, which Guernsey has generally followed in its negotiations with other jurisdictions in recent years. The text of the tax treaty incorporates some of the recent international standards designed to prevent base erosion and profit shifting (BEPS). Continue Reading

OECD Consulting on Transfer Pricing Aspects of Financial Transactions

OECD Consulting on Transfer Pricing Aspects of Financial Transactions

The OECD today called for stakeholders’ input on a discussion draft on financial transactions, which 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

Selective Tax Advantage to Starbucks: EU Court Hears the Netherlands

Selective Tax Advantage to Starbucks: EU Court Hears the Netherlands

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). 


At a hearing of the General Court of the European Union on July 2, the Dutch Government put forward three points to demonstrate that it did not provide selective tax advantages to Starbucks in violation of the EU state aid rules.Continue Reading

Further Three Tax Jurisdictions Sign BEPS Convention

Further Three Tax Jurisdictions Sign 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). 


Kazakhstan, Peru, and the UAE have signed the base erosion and profit shifting (BEPS) Multilateral Convention, the OECD has announced, adding that Estonia intends to sign the Convention on June 29.Continue Reading

Switzerland to Exchange 109 CbC Reports With 35 nations

Switzerland to Exchange 109 CbC Reports With 35 nations

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 Tax Administration (FTA) will exchange this month 109 country-by-country (CbC) reports of multinational enterprises’ (MNEs) with 35 foreign tax jurisdictions.Continue Reading

Transfer Pricing: The Intangible Assets Case

Introduction

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.Continue Reading

CCCTB: The concept and the effects in Cyprus and Malta

Introduction

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.Continue Reading

BEPS Convention to Enter Into Force in July

BEPS Convention to Enter Into Force in July

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’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.Continue Reading

Countries Agree to Reach Consensus on Digital Taxation by 2020

Countries Agree to Reach Consensus on Digital Taxation by 2020

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 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.Continue Reading