Transfer Pricing

News & Analysis as of

Revised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation

CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements in substantially more...more

Legal Alert: MTC Speaks with Potential Transfer Pricing Vendors

On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment...more

Marzen: Tax Court Upholds Transfer Pricing Adjustments

The decision of the Tax Court of Canada in Marzen Artistic Aluminum Ltd. v. The Queen (2014 TCC 194) is the latest addition to a growing body of Canadian judgments on the application of the transfer pricing rules in section...more

Alabama Joins Transfer Pricing Advisory Group to Develop New Service for the Multistate Tax Commission

Alabama has joined the District of Columbia, Florida, Georgia, Hawaii, Iowa, Kentucky, New Jersey, and North Carolina as members of the Arm’s Length Adjustment Services (ALAS) Advisory Group, a new project by the Multistate...more

MTC Launches Transfer Pricing Effort

On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more

Luxembourg: recent developments in transfer pricing and tax ruling practice

The Luxembourg tax authorities are currently carrying out transfer pricing audits, particularly for financing companies. When the transfer prices are not substantiated through proper documentation, the Luxembourg tax...more

Information Letter: Transfer Pricing in Russia: What is the Likelihood of an Audit?

On 20 November 2013 for the first time Russian taxpayers should have filed with controlling authorities notifications on controlled transactions (“Notifications”) in accordance with the new transfer pricing rules. According...more

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

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