UK tax advisers hail transfer pricing, diverted profits tax reform

The Chartered Institute of Taxation (CIOT) has welcomed proposed reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax.Continue Reading

New UN report on inclusive international tax co-operation

The United Nations (UN) Secretary General has published an advance, unedited report highlighting the role of the UN in promoting effective and inclusive international tax cooperation.Continue Reading

Vladimir Putin suspends tax treaties with ‘unfriendly’ countries

Russian President Vladimir Putin has suspended several tax treaties with “unfriendly” countries.

The suspension decree was signed on August 8. The decree includes tax treaties signed with the US, the UK, and Canada, and other countries that had imposed unilateral economic sanctions on Russia.

“In view of the need to take urgent measures in connection with the unfriendly actions of a number of foreign states against the Russian Federation, its citizens and legal entities, the President resolved to suspend a number of provisions of tax treaties with the United States of America, European Union countries and other unfriendly states,” an official statement from the President’s office notes.

The suspension was proposed by the Finance Ministry in March 2023.

International Tax Law Student Essay Writing Competition 2023

TP News is announcing its first annual International Tax Law Student Essay Writing Competition 2023.

We are now inviting original submissions from students enrolled in a full-time undergraduate law course around the world. Co-authorship is possible.

The submission must seek to identify and answer a point of law that involves interpretation of one or more provisions of a tax treaty. The essay should not be descriptive in nature and must show outstanding analysis, while adding to the existing tax treaty jurisprudence.

We will not accept submissions over 3,000 words. We do not accept footnotes or endnotes, use hyperlinks instead.

All submissions will go through two rounds of selection process. Based on an initial screening by TP News team, shortlisted submissions will be sent out for blind peer review. We, therefore, encourage students to avoid mentioning their names/affiliations anywhere in their essays. Please note that all submissions will be put through our standard plagiarism detection process.

The top three entries will be published on TP News.

Submissions must be emailed to us as Microsoft Word documents by 11:59 pm UTC on November 7, 2023. We expect to receive a high number of entries and would be unable to respond individually.

Winners will be announced on our website and social media handles in January 2024.

For questions or clarifications, please contact: editor@transferpricingnews.com

Australian thin capitalization tax bill flawed: CA ANZ

Australia’s Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023, which includes thin capitalization measures, is flawed in several respects, Chartered Accountants Australia & New Zealand (CA ANZ) has said.Continue Reading

Don’t impose digital services tax: US Chambers to Canada

The US Chamber of Commerce has urged the Canadian government to refrain from unilaterally imposing a digital services tax pending international agreement.Continue Reading

Jenny Austin named chair of ABA’s Transfer Pricing Committee

Jenny Austin has been named chair of the American Bar Association’s (ABA’s) Transfer Pricing Committee.

According to ABA, the Committee aims to establish itself as the “most important forum for global transfer pricing issues.” It will provide advice to members as well as US and foreign government agencies that administer transfer pricing rules.

Austin concentrates her practice on federal tax controversy and litigation, working across all industries, including medical device, pharmaceutical, health care, retail, and technology companies. Her tax controversy experience spans a diverse array of subject matter areas: transfer pricing, cross-border acquisition issues, debt-equity issues, settlement agreements, withholding, privileges, summons enforcement, and penalties. She also has experience with transfer pricing issues at the state level.

Ireland consulting on tax changes to tackle double non-taxation

Ireland’s Department of Finance is consulting stakeholders on new tax measures that would prevent double non-taxation arising from outbound payments to low or no tax jurisdictions.Continue Reading

138 tax jurisdictions agree on global tax reform, defer digital tax measures

138 tax jurisdictions have agreed an ‘Outcome Statement” on ways to move forward with historic, major reform of the international tax system.Continue Reading

Brazil consulting on new transfer pricing tax regulations

Brazil’s Special Secretariat of the Federal Revenue is consulting stakeholders on a draft Normative Instruction that would regulate the country’s new transfer pricing regime.Continue Reading

A&M Tax appoints transfer pricing expert Rasmus Steiness as Senior Director

Alvarez & Marsal Tax LLP has appointed transfer pricing expert Rasmus Steiness as a Senior Director.

Steiness will work with Managing Director Richard Syratt in London to help international clients solve increasingly complex transfer pricing issues.

Steiness brings more than 16 years of experience supporting banking, capital market, and fintech clients. He specializes in the alignment of tax and operating models, IP, and financial transactions.

Transfer Pricing Reform in Brazil and ‘Options Realistically Available’: New Tax Disputes Ahead?

Law No. 14596/2023 introduced new transfer pricing rules in the Brazilian tax system, in line with the arm’s length standard. The transfer pricing reform is a result of a long project carried out by the Brazilian Federal Revenue Office since 2018, with support from the Organization for Economic Cooperation and Development (OECD) and the United Kingdom (UK), aiming at convergence of Brazil’s transfer pricing rules and the OECD Transfer Pricing Guidelines.Continue Reading

Transfer pricing rules in UAE explained

Federal Decree Law No (47) of 2023 on the Taxation of Corporations and Businesses enforces transfer pricing rules and documentation requirements in the UAE to ensure that the pricing of transactions between related parties and connected persons, such as companies that are part of the same multinational enterprise (MNE) group, are not influenced by their relationships.Continue Reading

UK modernizing transfer pricing, diverted profits tax rules

UK government is seeking stakeholders’ views on potential reforms to the UK international tax legislation on transfer pricing, permanent establishment, and Diverted Profits Tax.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

OECD notes progress on tackling harmful tax practices

OECD notes progress on tackling harmful tax practices

Almost 50,000 exchanges of tax information have taken place to date in respect of 23,000 tax rulings, as per a new OECD report.

The 2021 Peer Review Reports on the Exchange of Information on Tax Rulings includes the latest peer review assessments for 131 jurisdictions in relation to the compulsory spontaneous exchange of information on tax rulings.

Released on December 14, this is the sixth annual peer review of the implementation of the BEPS Action 5 minimum standard on tax rulings, which aims to provide tax administrations with the necessary information concerning their taxpayers to efficiently tackle tax avoidance and other BEPS risks.

The new peer review results show that 73 jurisdictions are fully in line with the BEPS Action 5 minimum standard, with the remaining 58 jurisdictions receiving a total of 61 recommendations to improve their legal or operational framework to identify the relevant tax rulings and exchange information.

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

Panama Supreme Court on tax arbitration

By Rafael Rivera Castillo (Managing Partner, BDO, Panama)

Background

In an August 8 decision, the Panama Supreme Court of Justice declared unconstitutional several sections of the Tax Procedure Code (TPC). These provisions granted special adjudicating powers to private arbitration panels to solve tax disputes between the Directorate General of the Revenue (DGI) and taxpayers, including those related to international tax issues (such as the application of tax treaties and transfer pricing issues).Continue Reading

White & Case adds Carlos Martinez to global tax practice

Law firm White & Case LLP has roped in Carlos Martinez as a partner in the firm’s Global Tax Practice.

Martinez will be based out of Mexico. Martinez joins White & Case from Creel Abogados, S.C.

Martinez has extensive experience providing tax advice to domestic and multinational companies on corporate transactions. He also provides advice on international taxation, transfer pricing and tax litigation.

White & Case partner Sang I. Ji, Global Head of the Tax Practice, said: “Carlos brings a wealth of experience acting as tax counsel on complex, cross-border deals. Further strengthening our tax capabilities in Mexico through Carlos’s arrival will support the continued growth and development of our corporate practice in this key market.”

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

Australia gets over AUD 68 billion in corporate income tax

Australia gets over AUD 68 billion in corporate income tax

This year’s report represents 2,468 corporate entities, who paid a combined AUD 68.6 billion in income tax, AUD 11.4 billion or 19.8 percent more than the previous year and the highest since reporting began.Continue Reading

Inter IKEA Group paid less corporate income tax in 2022

Inter IKEA Group paid less corporate income tax in 2022

The amount of corporate income taxes paid by Inter IKEA Group decreased to EUR 322 million (EUR 398 million in the 2021 financial year). However, the total tax contribution increased slightly to EUR 1,996 million (EUR 1,916 million in the 2021 financial year).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

Pakistan court rules on taxability of EPC contracts

Engineering, procurement and construction (EPC) contracts and split contract arrangements (involving offshore supply contracts and onshore service contracts) have remained a key focus of Pakistani tax authorities. The tax implications for these transactions are influenced by the design of the transaction in question and the provisions of the applicable Double Tax Treaties (DTTs).

Recently, Pakistan’s Appellate Tribunal Inland Revenue (ATIR – second tier appeal forum) has allowed an appeal against the tax authority’s order for recovery of withholding tax, deductible while making payment for the offshore supply of machinery (ITA 377/KB/2019). As per the facts, the appellant, a Pakistani renewable energy project, imported machinery and equipment from a Chinese manufacturer. The onshore contract (construction, assembly and installation services) was signed separately with an associate of the equipment supplier, also resident in China and executed through a branch office registered in Pakistan, constituting a permanent establishment (PE). The taxpayer was held assessee-in-default due to the following facts:

  • The supplier of machinery and the provider of onshore service were associates.
  • Both offshore and onshore agreements were similar in language and signed by the same person.
  • The contract is essentially in the nature of an EPC contract and the location split of the EPC contract was made to avoid taxes due in Pakistan.

The tax authority inferred that the offshore supplier and onshore service provider, being PE of a separate company of the same group, must be considered a single entity for tax purposes. Lastly, the tax authority maintained that the offshore contract is subject to tax in Pakistan as per DTT between Pakistan and China, which is based on the UN Model Tax Convention (UN MTC) and contains a ‘force of attraction’ rule.

ATIR decided the appeal in favor of the taxpayer and relied on precedents involving DTTs with Germany and Italy to conclude that offshore supply contract/portion of composite contract cannot be subject to tax in Pakistan due to overriding effect of relevant DTTs. Moreover, ATIR held that:

  • The requirement to obtain specific withholding tax exemption was inapplicable in case of payments for import of goods where title to goods is transferred outside Pakistan and supply is not made between associates.
  • Tax authority was not authorized to discard the associated entity and treat Pakistani PE as the PE of offshore supplier for invoking force of attraction rule.
  • The so-called force of attraction rule is not applicable for taxation of EPC contracts in view of the guidance provided under the UN MTC.
  • The concept of Cohesive Business Operations (CBO) introduced in domestic tax law, including related amendments in the definition of PE and source rules for business income and restriction on exemption from withholding tax, may affect the tax position prospectively, i.e. from 1 July 2018 onwards.
  • In case of any conflict between domestic law and a DTT provision, the latter overrides the former. DTT override is applicable insofar as it provides for tax relief otherwise not available under the domestic law. In the context of attribution of profits to a PE, existing DTT does not contain any specific reference to the concept of CBO in Article 5.

ATIR has addressed a key issue involved in the taxability of EPC/splitting of contracts under the Pakistan-China DTT. The amendments relating to CBO are not tested yet, however, the judgement may still apply insofar as it has been held that the definition of PE as per DTT supersedes the domestic law.

Muzammal Rasheed is Chief Executive Officer of Enfoque Consulting (Private) Limited, Pakistan, a member firm of WTS Global.

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

What is Transfer Pricing, Definition, Overview under Indian law

Indian transfer pricing regulations were enacted via the Indian Finance Act 2001 by introducing  a separate code under Sections 92 to 92F of the Income- tax Act , 1961 (‘the Act’) read with Income- tax Rules, 1962 (‘the Rule’s) 10A to 10ETHD. The regulations are largely and principally based on OECD guidelines and describe the various transfer pricing methods, requirement for transfer pricing documentation, and contain penal provisions for non-compliance. The Indian regulations deal with intra-group transactions and is applicable from April 1, 2001.Continue Reading

Glencore’s transfer pricing tax victory: key takeaways

By Carmen McElwain (Partner, Minter Ellison, Melbourne, Australia)

On 21 May 2021 the High Court of Australia (comprised of Chief Justice Kiefel and Justice Gordon) heard and refused an application for special leave sought by the Commissioner of Taxation (Commissioner) in relation to the Full Federal Court’s decision in Commissioner of Taxation v Glencore Investments Pty Ltd (2020) [2020] FCAFC 187; 384 ALR 252 (Glencore). Continue Reading

Corporate Tax Rates of Turkey in 2021

By Kardelen Lule (ADMD / MAVIOGLU & ALKAN, Turkey) 

The rate of corporate tax was amended significantly with the Law No.7316 Amending the Law on Collection of Public Receivables and Certain Laws (“Law No.7316”) published in the Official Gazette dated April 22, 2021.

The rate which was earlier determined for 2018, 2019, and 2020 was 22%. Article 11 of the Law No.7316 amended the corporate tax rates by adding Temporary Article 13 to Corporate Tax Law No.5520 (“CTL”) which increased corporate tax rates to 25% for 2021 and to 23% for 2022. For institutions subject to special accounting periods (the regular period is January 1 to December 31), the mentioned rates will be applied to the earnings of these institutions for the accounting periods starting in the relevant year.Continue Reading

Thai Tax Authority Issues Notification on Transfer Pricing Methods

By Varapa Aurat (Consultant, Tilleke & Gibbins, Thailand) 

On May 6, 2021, a new transfer pricing notification from Thailand’s Tax Department was officially published in the Government Gazette. The Notification of the Director-General of the Tax Department Re: Income Tax (No. 400), which was first announced earlier in the year, prescribes the criteria, methods, and conditions for Tax Department officials on how to assess income and adjust expenses for transactions between related parties (as defined in Section 71 bis of the Tax Code) that engage in intercompany transactions where conditions between the two parties in their commercial or financial relations differ from those that would be made between independent parties (i.e., where the transaction is not an “arms length” transaction).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

Coca Cola asks US Tax Court to reconsider transfer pricing dispute

The Coca-Cola Company has requested the US Tax Court to reconsider a transfer pricing tax ruling it gave last year in favor of the Internal Revenue Service (IRS).

The tax ruling was given on November 18, 2020. According to Coca-Cola, the US Tax Court’s ruling raises fundamental questions of tax, administrative, and constitutional law warranting further consideration by a full Tax Court.

The facts of the tax dispute are as follows. Upon examination of the company’s 2007-2009 returns, IRS determined that the company’s methodology did not reflect arm’s length principle because it overcompensated the supply points and undercompensated the company for the use of its intellectual property.

The US tax authority reallocated income between the company and the supply points employing a comparable profits method that used the company’s unrelated bottlers as comparable parties. These adjustments increased the companys aggregate taxable income for 2007-2009 by more than USD 9 billion.

In its decision, the Tax Court said that the IRS did not abuse its discretion by reallocating income to the company by employing a comparable profits method that used the supply points as the tested parties and the bottlers as the uncontrolled comparables. The US Tax Court further held that the tax authority did not err by re-computing the company’s losses after the comparable profits method changed the income allocable to the company’s Mexican supply point, a branch of the company.

In a Motion for Reconsideration of findings or opinion filed on June 2,  the company said that “the IRS is attempting to impose billions of dollars in additional taxes on Coca-Cola in this case under a different tax calculation method than that on which Coca-Cola justifiably relied and which the IRS audited and approved for over a decade before retroactively requiring Coca-Cola to use a new and different method for tax years long past.  The IRS’s attempt is arbitrary, capricious, and unconstitutional.”

The company added that the US Tax Court has the opportunity to correct these fundamental errors now, and with the utmost respect, Coca-Cola asks the Court to reexamine its opinion in this nationally important, precedential tax case.

The US Tax Court enjoys substantial discretion to reconsider findings of fact and conclusions of law under Tax Court Rule 161, the company said.


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

African Tax Administration Form submits revised Pillar One proposals

African Tax Administration Form submits revised Pillar One proposals

The revised proposals respond to both the Inclusive Framework blueprint report released for public consultation in October 2020 and the recent proposals from the US to revise the blueprint proposals.Continue Reading

US Senator raises questions about Treasury’s international tax strategy

US Senator raise questions about Treasury’s international tax strategy

The letter states that “there is bipartisan consensus for ensuring that every country plays by the same rules, including China – as President Joe Biden recently said.  No OECD agreement should provide carve-outs or exceptions for our biggest foreign competitors, including China.”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

New UN transfer pricing manual released

New UN TP manual released

The Manual is focused on transfer pricing in a global environment, while it provides guidance on design principles and policy considerations. It also addresses the practical implementation of a transfer pricing regime in developing countries and shares examples of country practices from developing countries, such as Brazil, China, India, Kenya, Mexico, and South Africa.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

Fabrizia Lapecorella to chair OECD’s Committee on Fiscal Affairs from 2022

The OECD’s Committee on Fiscal Affairs has designated Fabrizia Lapecorella as the next Chair of the Committee beginning January 2022.

Lapecorella has served as Italy’s Director General of Finance since June 2008. As Director General of Finance, she is responsible for tax policy, domestic European and international, the governance of the Tax Agencies, the coordination of the IT infrastructure serving the whole Tax Administration, and the administrative services for the Tax Judicial system.Continue Reading

OECD releases peer review reports on tax treaty shopping and abuse

OECD releases peer review reports on tax treaty shopping and abuse

The data compiled for this peer review demonstrate that the BEPS Multilateral Instrument has been the tool used by the vast majority of jurisdictions that have begun implementing the Action 6 minimum standard, and that the MLI has started to impact tax treaties of jurisdictions that have ratified it.Continue Reading

OECD releases MAP arbitration profiles of 30 tax jurisdictions

OECD releases MAP arbitration profiles

The Arbitration Profiles have been developed to provide taxpayers with additional information on the application of Part VI of the MLI for each jurisdiction choosing to apply that Part. The Arbitration Profiles also allow those jurisdictions to make publicly available clarifications on their position on the MLI Arbitration.OECD releases MAP arbitration profiles of 30 tax jurisdictions
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

Outline and Considerations for the Pillar One Blueprint Proposals for Amount A

Outline and Considerations for the Pillar One Blueprint Proposals for Amount A

By Simon Webber (Managing Director, Duff & Phelps LLC, New York) & Ryan Lange (Director, Duff & Phelps LLC, New York)

On October 12, 2020 the OECD/G20 Inclusive Framework (IF) released the Report on Pillar One Blueprint. This is a working document that presents the IF’s current thinking on the scope and application of changes to the international tax system to address the Tax Challenges Arising from Digitalization.  Specifically, the OECD is seeking broader consensus and approval for its proposals before moving forward further into a more detailed design.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

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

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

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

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

Singapore to participate in International Compliance Assurance Programme from 2021

Singapore to participate in International Compliance Assurance Programme

The MNE’s suitability for ICAP will be considered on a case-by-case basis. The MNE may propose for participating tax administrations it wishes to involve in its ICAP risk assessment, which will be subject to the participating tax administrations’ agreement.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

Maldives promulgates its first Transfer Pricing Regulation

The Maldives Promulgates its first Transfer Pricing Regulation

By Husam Shareef (Partner, CTL Strategies, Maldives)

On June 10, 2020, the Maldives tax administration, Maldives Inland Revenue Authority (MIRA), issued the country’s first transfer pricing regulation. The Regulation is made pursuant to the new Income Tax Act, which came into effect from January 1, 2020. The Regulation sets out the rules to be followed by enterprises that are required to maintain transfer pricing documentation and stipulates the criteria which exempt enterprises from maintaining such documentation. The Maldives has had a corporate tax regime since July 18, 2011, however, this is the first time that taxpayers are required to follow a specific transfer pricing documentation requirement.Continue Reading

Customs valuation and related party transactions

Customs Valuation and Related Party Transactions

By Shilpa Goel (Tax Lawyer, India)

I am currently working on a case that involves questions of huge significance when it comes to related-party transactions and customs valuation. It is always good to begin with a caveat and I have two. The first is that the import in question pertains to the years 2002-2006, when the Indian custom valuation rules were somewhat different (from what they are now). The second is that I will not comment on the exact merits of the case but provide a broad overview of the legal and practical side of things.Continue Reading

Augmenting Loan Documentation in light of Chapter X of the OECD Transfer Pricing Guidelines

Augmenting Loan Documentation in light of Chapter X of the OECD TP Guidelines

By Stefanie Perrella (Managing Director, Duff & Phelps’, New York) and Zachary Held (Director, Duff & Phelps’, New York)

On February 11, 2020, the OECD released its Final Report, Transfer Pricing Guidance on Financial Transactions, (Final Guidance), which was simultaneously incorporated into the OECD Transfer Pricing Guidelines. With respect to inter-company loans, the new Chapter X of the Transfer Pricing Guidelines is not limited to considerations for interest rate pricing, but also includes a framework for assessing the instrument’s accurate delineation as debt. Going forward, taxpayers with lenders or borrowers in OECD countries should consider this new guidance and augment their documentation accordingly. Below are some of the items that these taxpayers should consider to offer a proactive defense of potentially scrutinized areas.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 Congresswoman introduces public country by country reporting Bill

US Congresswoman introduces public country by country reporting Bill

The report would include CbC financial filings for the information, including profits, taxes, employees, and tangible assets – that these corporations already provide to the IRS on an annual basis.Continue Reading

OECD issues further guidance on country-by-country reporting

OECD issues further guidance on CbC reporting

The additional interpretative guidance contains complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far.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

Mexican 2020 Tax Reform: key international tax proposals

By Ricardo Rendón (Partner, Chevez, Ruiz, Zamarripa y Cía, S.C., Mexico)

On September 8, 2019, the Executive Branch of the Mexican Government submitted to the Congress Tax Reform for 2020, which includes key tax changes to the country’s tax law primarily inspired by the OECD’s base erosion and profit shifting (BEPS) project.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

Delving into Hong Kong’s New Transfer Pricing Landscape

Delving into Hong Kong’s New Transfer Pricing Landscape

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Principal, Transfer Pricing Services, SKP Group)


On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill). 

This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations under BEPS Action Plans.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

Jill Weise to lead Duff & Phelps’ transfer pricing practice

Global advisory firm Duff & Phelps has announced that Jill Weise will succeed Michael Heimert as the Global Leader for the firm’s transfer pricing practice.

Weise has nearly 25 years of expertise in transfer pricing. She previously served as the firm’s transfer pricing practice leader for North America.
  Continue Reading

Indian tax authority sets new CbC reporting deadline for US subsidiaries

Indian tax authority sets new CbC reporting deadline for US subsidiaries

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)


In India, the 2016 Finance Act introduced a three-tiered transfer pricing documentation regime with a view to aligning the Indian transfer pricing documentation rules with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.

Accordingly, Indian subsidiaries of multinational groups were required to comply with new “master” and “local” files requirements and a new country-by-country reporting requirement from the 2016-17 financial year.Continue Reading

Transfer pricing expert Mark Madrian joins Valentiam Group

Transfer pricing expert Mark Madrian has joined Valentiam Group as a Partner in the firm’s West Coast practice.

Madrian has advised clients on complex cross-border transfer pricing and other international tax issues. He was recently recognized as a Leading Transfer Pricing Adviser by Legal Media.
Continue Reading

Saudi tax authority publishes draft transfer pricing bylaws

Saudi tax authority publishes draft transfer pricing bylaws

By Anas Salhieh  (Senior Tax Executive, Al Tamimi & Company, Riyadh, Saudi Arabia)


Saudi Arabia’s General Authority for Zakat and Income Tax has published for public comments draft transfer pricing bylaws as part of the Kingdom of Saudi Arabia’s commitment to the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading

BEPS MLI to enter into force in Australia in January 2019

BEPS MLI to enter into force in Australia in January 2019
From January 1, 2019, the BEPS MLI will operate to modify six of Australia’s 44 bilateral tax treaties. These include tax treaties with France, Japan, New Zealand, Poland, the Slovak Republic, and the UK.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

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

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

Mauritius tax authority issues guidance on place of effective management

Mauritius tax authority issues guidance on place of effective management

The majority of the Board of Directors’ meetings must be held in Mauritius, or the executive management of the company must be regularly exercised in Mauritius.

Continue Reading

India, Hong Kong tax treaty to take effect from April 2019

India, Hong Kong tax treaty to take effect from April 2019

The tax treaty provides for a low withholding tax rate of five percent for dividend payments. Interest, royalties, and fees are subject to a low withholding tax rate of ten percent.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

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

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

Australian Taxation Office, BHP Settle Transfer Pricing Dispute

Australian Taxation Office, BHP Settle Transfer Pricing Dispute

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 Australian tax authority has settled a transfer pricing dispute with BHP in relation to the mining giant’s marketing operations in Singapore.
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

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.
Continue Reading

Transfer Pricing Compliance in China: Preventing Disputes is Key

China’s colossal economy and its predominant role within the global market result in the emergence of an increasing interest towards China’s transfer pricing regime. Since China is not a member of the OECD, any transfer pricing endeavor goes far beyond the classic transfer pricing practices, though.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

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

Hong Kong Gazettes Enhanced R&D Deduction

Hong Kong Gazettes Enhanced R&D Deduction

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). 


Hong Kong Government has gazetted law to allow enhanced tax deduction for expenses incurred by business enterprises on research and development (R&D) activities in Hong Kong.

The measure was announced by Carrie Lam, Chief Executive of Hong Kong, in her 2017 Policy Address.Continue Reading

Indian Tax Tribunal Allows Claim of Expenses by Mauritian PE

Indian Tax Tribunal Allows Claim of Expenses by Mauritian PE

By Ritu Shaktawat (Partner, Khaitan & Co, India) and Shabnam Shaikh (Principal Associate, Khaitan & Co, India)

In a decision delivered on October 5, India’s Income Tax Appellate Tribunal, New Delhi ruled that the Indian Income Tax Act cannot limit the claim of expenses of a permanent establishment in the absence of such limitation in the India-Mauritius tax treaty.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

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

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

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

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

New Zealand Reveals Details of New R&D Tax Incentive

New Zealand Reveals Details of New R&D Tax Incentive

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). 


New Zealand Government has revealed details about the new research and development (R&D) tax incentive aimed at encouraging businesses to invest more in R&D activities.

The rate for the tax incentive will be set at 15 percent for income years starting 2019-20. All businesses, regardless of legal structure, will be eligible to claim the tax incentive.Continue Reading

Australia Seeking Input on Digital Economy Taxation

Australia Seeking Input 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 Australian Government on October 2 launched for public comments a consultation document aimed at creating a fairer and more sustainable corporate tax system for the digitalized economy.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

Cameco Wins Transfer Pricing Tax Dispute

Cameco Wins Transfer Pricing Tax Dispute

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 Tax Court of Canada has ruled in favour of leading uranium miner Cameco in a CAD2.2bn transfer pricing dispute with the Canada Revenue Agency (CRA).

Cameco had disputed reassessments issued by CRA for the 2003, 2005, and 2006 tax years.Continue Reading

Israel Introduces New Transfer Pricing Safe Harbor Rules

Israel Introduces New TP Safe Harbor Rules

By Adv. (Eco.) Eyal Bar-Zvi (Partner and Head of Transfer Pricing, Herzog Fox & Neeman)

The Israel Tax Authority, on September 5, 2018, published two safe harbor Circulars (which remained in draft mode for several months), noting the tax authority’s expected profit levels for marketing services and for low-risk distributorship activities carried out in Israel by multinational entities (MNEs), and providing guidance on non-value-added services.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

Transfer Pricing Regulations Revised in Nigeria: Some Highlights

Transfer Pricing Regulations Revised in Nigeria: Some Highlights

By Amaka Samuel Onyeani (Senior Manager, Transfer Pricing, Andersen Tax, Nigeria) & Abisola Agboola (Assistant Manager, Transfer Pricing, Andersen Tax, Nigeria)

Nigeria’s Federal Inland Revenue Service (FIRS) recently released the revised Income Tax (Transfer Pricing) Regulations, 2018 (the Transfer Pricing Regulations). The Transfer Pricing Regulations are one of the efforts of the FIRS in improving the administration of transfer pricing in the country, increasing revenue collection via taxes, and protecting Nigeria’s tax base.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

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

Hybrid Mismatch Rules Enacted in Australia

Hybrid Mismatch Rules Enacted in Australia

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 Treasury Laws Amendment (Tax Integrity and Other Measures No.2) Act, 2018 – which gives effect to the OECD Hybrid mismatch rules in Australia – received Royal Assent on August 24.Continue Reading

India Concluding More Bilateral Advance Pricing Agreements

India Concluding More Bilateral Advance Pricing Agreements

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 Indian tax authority, Central Board of Direct Taxes, has published its second annual report on advance pricing agreement (APA) highlighting the progress made in 2017-18.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

Indian Tax Authority Extends ‘Significant Economic Presence’ Consultation Deadline

Indian Tax Authority Extends ‘Significant Economic Presence’ Consultation Deadline

India’s tax authority has extended the earlier deadline of August 10 to submit comments on the newly introduced “significant economic presence” test to tax profits of foreign businesses.Continue Reading

New Zealand Issues Draft BEPS Guidance

New Zealand Issues Draft BEPS Guidance

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). 


New Zealand Inland Revenue is seeking public input on draft tax guidance aimed at helping businesses comply with the Taxation (Neutralising Base Erosion and Profit Shifting) Act, which was enacted earlier this year.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

MNE Tax Avoidance Law a ‘Major Victory’ for Australia

MNE Tax Avoidance Law a ‘Major Victory’ for Australia

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). 


Over 40 multinational enterprises (MNEs) have restructured their business operations in response to Australia’s crack down on MNE tax avoidance law, ATO Deputy Commissioner Mark Konza has said.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 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

Australia Passes Law to Give Force to BEPS Convention

Australia Passes Law to Give Force to 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 Australian Parliament on August 16 passed a legislation to give the force of law to the OECD’s Multilateral Convention to implement tax treaty-related measures to tackle base erosion and profit shifting (BEPS).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

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

Australian Taxation Office Issues Draft Guidance on Related Party Financing Arrangements

Australian Taxation Office Issues Draft Guidance on Related Party Financing Arrangements

The Australian Taxation Office (ATO) has published for public comments Schedule 2 to Practical Compliance Guideline (PCG) 2017/4DC, which discusses the tax authority’s  compliance approach to tax issues relating to cross-border, related-party financing arrangements and related transactions.Continue Reading

US Transfer Pricing Examination Process: A Critique

US TP 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.

Continue Reading

Taiwan Begins International Tax Training for 2018

Taiwan Begins International Tax Training for 2018

Taiwan’s Finance Ministry is holding the 2018 International Tax Academy from July 30 to August 17 this year.

The event was launched in 1984 and is conducted every year in cooperation with the School of Law of Southern Methodist University.Continue Reading

Tax Bill Seeks to Improve Australia’s Thin Capitalization Regime

Tax Bill Seeks to Improve Australia’s Thin Capitalization 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 Australian Treasury has published for comments a draft tax Bill that would implement two key changes to improve the country’s thin capitalization regime. The changes – first proposed in the 2018-19 Budget – are intended to apply from income years beginning on July 1, 2019.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

New Mexican Transfer Pricing Adjustment Regulations Explained

New Mexican TP 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

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.

‘Significant Economic Presence’ – Missing Pieces of the Indian Tax Puzzle!

‘Significant Economic Presence’ – Missing Pieces of the Indian Tax Puzzle!

By Ritu Shaktawat (Associate Partner, Khaitan & Co, India) and Krutika Chitre (Associate, Khaitan & Co, India)

Ritu Shaktawat and Krutika Chitre of Khaitan & Co discuss the consultation document addressing the tax challenges of digital economy released by Indian’s Central Board of Direct Taxes on July 13, 2018.

Soon after having introduced ‘Google Tax’ in 2016, India becomes one of the first tax jurisdictions to treat ‘significant economic presence’ of a foreign enterprise as its taxable presence in India (effective from April 1, 2018 (that is, from assessment year 2019-20)).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

Australia Revising ‘Significant Global Entity’ Definition

Australia Revising ‘Significant Global Entity’ Definition

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 Australian Government is consulting stakeholders on a law that would extend the definition of a “significant global entity” to ensure multinational tax laws apply uniformly to all relevant entities.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

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

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