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.
On March 8, 2018, the Australian Government released for public comments revised exposure draft legislation aimed at tackling hybrid mismatch arrangements.
In a first, the European Commission has stressed that tax rules in seven EU member states facilitate corporate tax avoidance by multinational enterprises (MNEs).
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.
On March 5, 2018, the Hong Kong Government launched an online portal to enable Hong Kong entities to file their country-by-country (CbC) reports. The Portal can be accessed through: https://aeoi.ird.gov.
The arm’s length principle treats the members of a multinational enterprise (MNE) as operating in separate entities, rather than as inseparable parts of a single, unified business. Therefore, it is required that MNEs follow the same pricing policy for intra-group and uncontrolled transactions, under comparable circumstances. Otherwise, the controlled companies shall take the necessary measures and adjust their profits by reference to the conditions, which would have obtained between independent enterprises.
The UK Government has published an Order, which would update the definition of “transfer pricing guidelines” in the UK legislation.
David Lewis has joined Duff & Phelps’ as a managing director in the firm’s transfer pricing practice. Lewis will be located in Melbourne, Australia.
In a 24-page long letter to the country’s Parliament, Dutch State Secretary for Finance, Menno Snel, has set out a detailed tax plan to tackle multinational tax avoidance, including measures to prevent the internationally-oriented Dutch tax system from being used as a conduit to tax havens.