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.Continue Reading
Transfer Pricing
Latest worldwide transfer pricing news, updates, and analysis
New OECD Guidance on Hard-to-value Intangibles, Profit Split Method
On June 21, 2018, the OECD released two reports setting out key guidance on the application of the approach to hard-to-value intangibles, and on the application of the transactional profit split method, as part of its work on base erosion and profit shifting (BEPS) project.Continue Reading
Switzerland to Exchange 109 CbC Reports With 35 nations
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
OECD Report Card on CbC Reporting Implementation Out
60 out of 90 countries have introduced tax legislation to implement country-by-country (CbC) reporting obligation for multinational enterprises (MNEs), in line with Action 13 of the base erosion and profit shifting (BEPS) project, according to a May 24 OECD report.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
India’s CbC Reporting Requirement Clarified
By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)
As an active participant in the OECD’s base erosion and profit shifting (BEPS) project, India has implemented nearly all the BEPS recommendations and has taken several steps to amend the country’s domestic tax laws appropriately. The Indian Finance Act, 2016 implemented BEPS Action Item 13 by introducing a three-tiered transfer pricing documentation structure and made it effective from the 2016-17 financial year.Continue Reading
Indian Tax Authority Consulting On BEPS Action 5 Changes
The Indian tax authority has published for public comments a draft Notification, which will implement the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project.Continue Reading
OECD Issues Further Guidance on PE Profit Attribution
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.Continue Reading
Countries Agree to Reach Consensus on Digital Taxation by 2020
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