News & Analysis as of

Transfer Pricing

Focus on Tax Strategies & Developments - April 2017

by McDermott Will & Emery on

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

China updates special tax adjustment measures: new rules go into effect May 1

by DLA Piper on

China's State Administration of Taxation (SAT) has released the Administrative Measures on Special Tax Investigation Adjustments and Mutual Agreement Procedures in the Public Notice [2017] No. 6 (Bulletin 6). Bulletin...more

Law à la Mode: The future of retail; Green fashion; E-commerce in China; Brexit update: trademarks and design; and more (UK) Issue...

by DLA Piper on

Management, a Belgian national and expert on retail management and customer experience for fashion, department stores and home improvement retailing. He tells us about the changes he has seen in the retail sector over the...more

Russia clarifies procedures for Bilateral Advance Pricing Agreements

by DLA Piper on

On 17 March 2017 the Ministry of Finance of Russia (MoF) posted a draft order on the procedure for conclusion of bilateral advance pricing agreements (APAs) with the authorised bodies of foreign states. This draft order fills...more

IRS Issues Draft Form and Instructions for Country-by-Country Reports

by Alston & Bird on

Country-by-Country (CbC) reporting is now generally required for the ultimate parent of a U.S. multinational enterprise (MNE) for tax years that begin on or after June 30, 2016. On January 11, 2017, the IRS released a draft...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

by Foley & Lardner LLP on

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

RF Supreme Court consolidates court practice on the application of transfer pricing and thin capitalization rules

by Dentons on

On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article...more

Are you in compliance with Colombia's transfer pricing rules?

by Dentons on

Colombian law requires income taxpayers to file an informative return and supporting transfer pricing documentation in certain circumstances. The following summary will help determine if you or your business are required to...more

New Circular on Intra-Group Financing Activities

by Dentons on

On 27 December, 2016 the Luxembourg Tax Authorities issued the new Circular LIR n°56/1-56bis/1 on the tax treatment of entities engaged in intra-group financing activities. The new circular LIR n°56/1-56bis/1 (New...more

Is Your Customs Compliance BEPS Ready?

by Bennett Jones LLP on

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

New transfer pricing requirements in Latin America under BEPS

by DLA Piper on

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and...more

Base erosion and profit shifting - new regulations

by Hogan Lovells on

International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more

Colombia's tax bill - transfer pricing updates

by Dentons on

Colombia's newest tax bill, enacted on December 29, 2016 through Law 1819 of 2016, modifies (among others) the following sections of the tax code, related to the transfer pricing regime...more

Kyiv Tax Newsletter (Ukrainian)

by Dentons on

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

Kyiv Tax Newsletter

by Dentons on

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

Revamping of the Luxembourg transfer pricing rules applicable to intra-group financing transactions

by Dechert LLP on

The Luxembourg direct administration published Circular L.I.R. n° 56/1 – 56bis/1 applicable to companies carrying out intra-group financing transactions (the Circular) on 27 December 2016. The Circular has replaced two...more

New Amendments to the Tax Code

by Dentons on

On 16 December 2016 the President of the Republic of Azerbaijan signed a law amending the Tax Code (the “Amendment Law”). These are the long-awaited amendments whose adoption was expected after the President signed on 4...more

Transfer pricing rules to change in Ukraine from 2017

by DLA Piper on

On December 21, 2016, the Verkhovna Rada of Ukraine approved in the second reading the Draft Law "On Amending the Tax Code of Ukraine (on the Improvement of Investment Climate in Ukraine )" No. 5368. The law has been sent to...more

World Bank publishes Transfer Pricing Handbook for developing countries

by DLA Piper on

On 23 December 2016, the World Bank Group published a transfer pricing handbook "Transfer Pricing and Developing Economies: A Handbook for Policy Makers and Practitioners". The Handbook, which comprises eight chapters...more

Country by Country: Spain

by DLA Piper on

The new Spanish Corporate Income tax Regulations were approved on 11 July 2015 through the Royal Decree 634/2015, which complement the provisions included in the Spanish Corporate Income Tax Law (Law 27/2014) that entered in...more

Country by Country: United Kingdom

by DLA Piper on

Introduction - The UK CbC reporting regulations ("The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016") were made on 26 February 2016....more

Country by Country: Germany

by DLA Piper on

In Germany, CbC reporting has not yet been incorporated into domestic laws. However, draft legislation is currently being processed by the legislative bodies (Bundestag and Bundesrat) and is likely to be enacted this year....more

Country by Country: Portugal

by DLA Piper on

The Portuguese CbC reporting rules were approved in March of 2016 by the Portuguese Budget Law for 2016 (“PBL”). The PBL included a provision (article 121.º-A) in the Portuguese Corporate Income Tax Code foreseeing new...more

Country by Country: France

by DLA Piper on

CbC reporting was introduced into French legislation by the Finance Bill 2016. The new provisions, set forth under article 223 quinquies C of the French tax code, are effective for fiscal year ("FY") beginning on or after 1...more

Base erosion and profit shifting: Brazil proposes CbC reporting for multinationals - top points

by DLA Piper on

The Brazilian Federal Revenue (RFB) has released the draft of a proposed Normative Rule (Public Consultation RFB No. 11/2016) regulating the implementation of country-by-country reporting via a CbC Report. The proposed draft...more

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