Transfer Pricing

News & Analysis as of

Base erosion and profit shifting - new regulations

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

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)

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

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

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

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

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

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

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

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

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

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

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

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

Intellectual Property Bulletin - Fall 2016

Mean Girls v. The Right of Publicity: Lessons Learned From the Lohan and Gravano Lawsuits - On September 1, 2016, a New York appellate court ended two closely watched right of publicity lawsuits brought by Lindsay...more

Revitalized by Increased State Interest, the MTC Transfer Pricing Committee Pushes Ahead

On November 9, the Multistate Tax Commission’s Transfer Pricing Committee met to continue its effort to develop and implement a comprehensive transfer pricing program, through which states can identify and remedy allegedly...more

Ethiopia introduces new transfer pricing directive

Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 ("the Directive") issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the...more

Newsletter TAX – Transfer Pricing Ecuador

The Internal Revenue Service in Ecuador (hereinafter, “SRI” for its acronym in Spanish) established  regulations in regards to indirect expenses in order to apply a deductibility threshold for these expenses when calculating...more

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

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