News & Analysis as of

Transfer Pricing

Polish Ministry of Finance publishes a draft bill proposing significant changes to corporate income tax

by DLA Piper on

The Polish Ministry of Finance has published a draft bill that proposes significant changes to, among other things, the Act on Corporate Income Tax (Bill). Its aim is to close loopholes in the corporate tax system. The Bill...more

The Mutual Agreement Procedure: A Taxpayers' Tool Reinvented

by DLA Piper on

Tax risks of multinational enterprises are expected to continue to increase post-BEPS as tax authorities globally increase their scrutiny on their cross-border tax transactions. This trend is anticipated in the OECD/G20...more

BEPS Update: OECD Multilateral Instrument Signed

by Proskauer - Tax Talks on

On June 7, 2017, ministers and high-level officials of 68 jurisdictions convened to formally sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS),...more

More than 60 countries sign OECD multilateral convention to counter base erosion and profit shifting

by DLA Piper on

This week's signing ceremony for the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS marks a new and important milestone in the international tax agenda to tackle perceived abusive...more

Transfer pricing compliance in Russia. Part 3. Stages of transfer pricing compliance

by Dentons on

Dentons’ Tax and Customs practice congratulates its clients and friends on the end of the first stage of transfer pricing compliance for 2016 – the filing of the notification of controlled transactions completed in 2016!...more

Manufacturing Matters May 2017

by DLA Piper on

As mentioned in the last issue of Manufacturing Matters, “Smart Manufacturing”, including automation, is gaining momentum. A number of leading global manufacturers have already adopted it, and according to The Annual...more

Tax administrations prepare for automatic exchange of CbC reports - are you ready? Three takeaways

by DLA Piper on

OECD announced that another important step has been taken to implement country-by-country (CbC) reporting requirements, as signatories to the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (the CbC...more

Risky Business — Intracompany Transfers at Price v. Cost

The FAR cost principles and their DAR and ASPR predecessors have long provided that “materials, supplies, and services” can be transferred between “divisions, subdivisions, subsidiaries, or affiliates of the contractor” at a...more

Implications of the Chevron Case on the Pharmaceutical Industry

by K&L Gates LLP on

In recent years, the Australian Taxation Office (ATO) has focused much energy in the transfer pricing arena, firstly due to the issue becoming part of the OECD's ongoing investigation into international tax practices and...more

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

by DLA Piper on

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the...more

ATO wins Full Federal Court decision on Cross Border Financing - Chevron Australia Holdings case

by DLA Piper on

In a major Australian transfer pricing decision on Friday 21 April 2017, the Full Federal Court dismissed Chevron Australia Holdings Pty Ltd's (CAHPL) appeal related to the deductibility of interest on the Australian dollar...more

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

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