Transfer Pricing

News & Analysis as of

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more

MTC State Transfer Pricing Program Looms on the Horizon

Transfer pricing is usually considered an international affair, but state governments, like there larger national brethren, have increasingly, and painfully, come to realize that inter-state transfer pricing has become a...more

Legal Alert: MTC Seeks More Bucks Using Transfer Pricing Audits

The Multistate Tax Commission plans to announce that they are accelerating their development of a transfer pricing audit program by soliciting the assistance of Dan Bucks, the former MTC Executive Director and Montana...more

Decreto Destinazione Italia: La Strada Del Concordato Si Fa Piu' Difficile Per Il Debitore

Il 21 febbraio 2014 è stato convertito in legge, con modificazioni, il decreto legge 145/2013 recante interventi urgenti di avvio del piano “Destinazione Italia” (il “Decreto Destinazione Italia”). Il Decreto Destinazione...more

IRS Releases Its “Roadmap” Of The Transfer Pricing Audit Process

The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process, emphasizing up-front planning and a fact-based approach for examiners. ...more

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more

International Tax News - February 2014

IRS RELEASES ITS “ROADMAP” OF THE TRANSFER PRICING AUDIT PROCESS - The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process,...more

Australia’s new transfer pricing laws overlap the thin cap rules: new challenges for taxpayers

The overlap of Australia's new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers - particularly for the arm's length amount-of-debt...more

The 3 Most Significant Tax Matters for Multinationals in 2014

What is the most significant tax consideration facing multinationals in 2014? That’s the question we recently put to leading tax advisors, asking for their quick take on the matter as we launch our new 'Need to Know' series....more

International And Transfer Pricing Audits: Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar

At the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar on February 18, 2014, the CRA provided an update on international and transfer pricing audits. The slides can be found here. The discussion was led...more

The Shadow Transfer Pricing Rules: Crediting Foreign Taxes

At the end of the 2013, the IRS issued, in the form of a Chief Counsel Advice [1] (CCA 201349015), its view on the applicability of transfer pricing concepts to transactions involving disregarded entities (“DEs”) in the...more

Transfer Pricing Audit Roadmap

Code Section 482 requires that transactions between related companies be conducted based on “arms-length” pricing. The purpose of the section is to foreclose inappropriate pricing methods that attempt to shift profits to...more

OECD releases new discussion draft on transfer pricing documentation – a template for multinational reporting of global business...

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released its proposed updated guidelines on transfer pricing documentation, including country-by-country reporting (CbC),...more

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

2014 Transfer Pricing Resolutions

Happy New Year! It’s time to make your 2014 transfer pricing resolutions: read a good book, learn a new language and, of course, exercise, exercise, exercise. 2013 was a very active year from a transfer pricing...more

The McKesson Case – A Holiday Gift From Justice Boyle Of The Tax Court Of Canada: Ask And You Shall Receive(able) – Canada’s...

On Friday, December 20th, the Tax Court of Canada released the long-awaited and lengthy decision of Justice Patrick Boyle in McKesson Canada Corporation v. The Queen, a case involving transfer pricing adjustments under...more

Supreme Court Endorses Key Tax Principle: Tax Law Should Follow Private Law Agreements

The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, “tax law applies to transactions governed by, and the nature and legal...more

IRS proposes changes to Competent Authority and APA procedures: comments requested by 3/20/2014

The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and other provisions of US...more

International Tax News - December 2013

CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT - The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement. The IGA is the first step in bring the Cayman fund industry...more

New Dutch transfer pricing decree: incorporating case law, bringing clarity

The Dutch Ministry of Finance has released a new transfer pricing Decree that is already in effect. The New Decree, announced in late November, supersedes two earlier Decrees, that of 30 March 2001 (IFZ 2001/295) and...more

Focus on Tax Controversy - December 2013

In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more

India: more certainty for investors, or less? Actions to take re the latest on GAAR, TP safe harbors, subsidiary PE

Recent legislative and case-law developments have clarified India’s position on a number of tax and transfer pricing issues. While many of these developments are intended to increase certainty for foreign investors, a number...more

Colombia issues tax havens list: 4 things to note for those doing business in Colombia

Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia from or through any of these tax haven jurisdictions. The Tax Havens list was issued under...more

Transfer Pricing: Major Developments for Certain French Companies Engaging in Transactions with Related Entities

The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies. New Provisions of French Law - Provisions Already Adopted - Within the...more

OECD Summarizes Transfer Pricing Documentation Questions Ahead of November Consultation

The Organisation for Economic Co-operation and Development (OECD) has issued a memorandum in connection with the planned overhaul of transfer pricing documentation rules under its action plan to address base erosion and...more

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