Transfer Pricing

News & Analysis as of

State aid – the European Commission charges forward

This note provides an update on the EU state aid decisions and aims to put recent developments in context. We review the current state of the state aid investigations, provide some political context, touch on the US...more

With a New Name, MTC Transfer Pricing Program Moves Forward

On August 18, 2016, the Multistate Tax Commission’s Transfer Pricing Committee voted to adopt an Information Exchange Agreement, which permits states to share taxpayer information with other states participating in the...more

Anti-BEPS Ukraine style: de-offshorization initiative launches

Leakage of profits to offshore locations and tax evasion through aggressive planning has always been a hot topic in Ukraine. However, it must be said that, with the exception of the introduction of transfer pricing rules in...more

OECD BEPS Working Groups issue three discussion drafts

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released three documents: its proposed updated guidelines on the application of the transactional profit split, draft...more

MTC Annual Meeting Update: MTC Approves Model Sales and Use Tax Nexus Statute

The Multistate Tax Commission (“MTC”) held its Annual Commission Meeting on July 27, 2016. Of note, the MTC voted to adopt the Model Sales and Use Tax Nexus Statute. In addition, the Arm’s-Length Adjustment Service Committee...more

Further down the rabbit hole we go: Additional guidance released by OECD on the attribution of profits to permanent establishments

Action 7 of the BEPS Action Plan1 tackles the definition of permanent establishment (PE) in order to prevent the artificial avoidance of a PE status through the use of commissionaire arrangements and the specific activity...more

China makes major changes to transfer pricing documentation and country-by-country reporting requirements

China’s State Administration of Taxation (SAT) on 13 July released on its website guidance that makes substantial changes that apply to multinationals’ transfer pricing compliance obligations for the 2016 fiscal year....more

Brussels Tax Alert

A. Beneficial tax regime - Law 89/1967 "On the Establishment in Greece of Foreign Commercial and Industrial Companies" was meant to attract foreign investments in Greece, by providing a wide range of benefits regarding...more

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Amid the Economic Uncertainties of the Brexit, New Challenges in Corporate Tax Structuring for UK Companies (And Their Parents,...

The June 23, 2016 “leave” Brexit vote has left many in the business and legal communities stunned, and while uncertainties abound, there is no doubt that wading through the economic and administrative complexities of exiting...more

New Public Country-by-Country Reporting of Financial Information Proposed by European Commission

Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing...more

MTC Committee Pushes Forward with Bare-Bones Transfer Pricing Program

On May 16, 2016, the Arm’s-Length Adjustment Service Committee (“ALAS Committee”) of the Multistate Tax Commission met via teleconference to move forward with its transfer-pricing program. The ALAS Committee is targeting a...more

The Legacy of Michigan Senator Levin and Offshore Taxation Issues

When Senator Levin, the Democrat from Michigan, announced his retirement from the Senate in 2014, you could hear a collective sigh of relief from the corporate business community. Senator Levin had dedicated himself to...more

WCO Technical Committee on Customs Valuation Sanctions Use of Transfer Pricing Studies

To support the use of transfer pricing studies as an aid in establishing that prices paid or payable are not influenced by the relationship between vendor and purchaser, the World Customs Organization (WCO) has sought for...more

Update: Transfer Pricing and Customs Valuation Case Study Published on WCO Website

On 29 April 2016 the World Customs Organization (WCO) published the full text of a case study where Customs takes into account a company's transfer pricing study based on the transactional net margin method (TNMM) in...more

WCO TCCV approves case study on TNMM transfer pricing documentation and customs valuation

During the week of 18-22 April 2016 the World Custom's Organizations Technical Committee on Customs Valuation (TCCV) held its 42nd Session in Brussels. At this session a new instrument was approved by the TCCV that contains a...more

Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador

A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax revenues simply due to...more

China Customs authorities enhance monitoring of intercompany prices and royalty payments

China’s General Administration of Customs (GAC) has released an amendment to the Import and Export Declaration Documents Standards. Among many changes, the Amendment now requires Chinese entities with importing and exporting...more

MTC Arm’s-Length Adjustment Service (Part II): “An Expression of Grief, Pity, or Concern”

Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more

[Webinar] Recent Trends and Developments Affecting the IT Services and E-Commerce Sector Between the U.S. and India - April 18th,...

Leading law firms Pepper Hamilton and Khaitan & Co. will be joining together to discuss: • Start-Up India - India’s newly adopted regime for start-ups and what it means for foreign investors and IT and e-commerce providers...more

Financial Regulatory Developments Focus - March 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

US Banking Agencies Issue Interagency Guidance on Funds Transfer Pricing Related to Funding and Contingent Liquidity Risks

The US Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System issued interagency guidance on funds transfer pricing (FTP) practices...more

Russian Transfer Pricing in 2016

Dentons’ Tax practice would like to remind you that, for transactions completed in 2015, the notice of controlled transactions must be filed with the tax authority at the taxpayer’s location (place of residence, registration)...more

Mining in Africa – getting in sync with the cycle

With one third of the world’s mineral reserves and two thirds of the world’s diamond production, Africa should have basked in the era of roaring commodity prices and booming optimism. Over the last decade, Africa’s average...more

Tax Update: Tax Ruling Transparency in the EU - What You Need to Know

In the wake of the final OECD BEPS reports issued in October, the European Council adopted amendments to Directive 2011/16/EU providing for the automatic exchange of information concerning advance cross border rulings (ACBR)...more

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