Transfer Pricing

News & Analysis as of

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Australian Tax Update - October 2015

The Chevron decision provides critically important guidance on both the 'old' (Division 13) and 'new' (Subdivision 815-A) transfer pricing laws in Australia. While not dealing specifically with Subdivisions 815-B to D, the...more

Managing The Changing Tax Landscape: The OECD’s BEPS Recommendations Will Impact Every Multinational

The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that...more

The EC Challenge on Tax Rulings. Why it’s Important that Your Business Acts Now in Relation to EU Challenges to Tax Rulings

21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more

European Commission adopts first two decisions in EU tax probe in push for corporate tax reform

On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and...more

The European Commission’s New Pandora’s Box – Reopening Final Tax Rulings as a Form of “State Aid”

In Short - The European Commission (Commission) has adopted a decision on 21 October 2015 on the tax rulings – also referred to as “comfort letters” – granted by Luxembourg to Fiat Finance and Trade (FFT) and by The...more

EU Prohibits "Fiscal Aid"

The European Commission has ruled that two decisions made by national tax authorities artificially reduced the tax burden on the companies involved. ...more

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. ...more

Tax Policy Update

After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

Kyiv Tax Newsletter (Ukrainian) - October 2015

Amendments to the State Budget of Ukraine for 2015 - On September 17, 2015 the Verkhovna Rada of Ukraine adopted the Law on Amendments to the Law of Ukraine on State Budget for 2015 No. 704-VII. According to the...more

Kyiv Tax Newsletter - October 2015

Amendments to the State Budget of Ukraine for 2015 - On September 17, 2015 the Verkhovna Rada of Ukraine adopted the Law on Amendments to the Law of Ukraine on State Budget for 2015 No. 704-VII. According to the...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

BEPS Deliverables Landing at China SAT Releases Draft New Transfer Pricing Administration Measures For Public Comments

On September 17, 2015, China's State Administration of Taxation (SAT) released the draft of "Implementation Measures of Special Tax Adjustment" (the "Draft") for public comments. As a response to the deliverables of the Base...more

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

Tax Policy Update

As in the 9 percent "amusement tax" that the city of Chicago recently extended to online streaming services like Netflix and Amazon Prime, triggering a series of lawsuits alleging that the newly expanded tax was illegally...more

"IRS Implements Final Changes to Advance Pricing Agreement Process"

On August 12, 2015, the IRS issued Rev. Proc. 2015-41, which sets out the procedures for pursuing advance pricing agreements (APAs). The new revenue procedure replaces Rev. Proc. 2006-9 and finalizes revenue procedures...more

Successful Strategies for Doing Business in Asia: Korea (Updated)

WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more

Changes to Transfer Pricing Regulations

On 7 August 2015 the President of Ukraine has signed the Law ?609-VIII "On Amendments to the Tax Code of Ukraine (in respect of transfer pricing)" (the Law), which was previously adopted by Ukrainian parliament. The Law...more

Country-by-Country Reporting in the EU: Spain Adopts Regulations and the European Parliament Votes for Public Disclosure

On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect...more

Not So Fast: ALAS Fails to Attain Sufficient State Support

At the Multistate Tax Commission (MTC) Executive Committee Meeting in Spokane, Washington, the Arm’s-Length Adjustment Service (ALAS) Advisory Group provided an update on its transfer pricing effort. On May 7, 2015, the...more

Australian Taxation Office issues new Practice Statement on Advance Pricing Arrangements

The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate...more

Tax Court Overturns Important Transfer Pricing Regulations

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under code section 482 that says taxpayers have to take into...more

Ukraine: New Rules for Advance Pricing Agreements Adopted

On 25 July 2015 the Cabinet of Ministers of Ukraine published an order on the conclusion of advance pricing agreements ("APA") in respect of controlled transactions for transfer pricing purposes* ("the APA Order"). The APA...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

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