Transfer Pricing

News & Analysis as of

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

Doing Business in Canada

Forms of Business Organization in Canada - Canadian business laws are well developed. Several different types of business structures are available in Canada. Each features unique advantages and disadvantages. ...more

Bueller? Bueller? MTC Still Calling on States to Join ALAS Program

The Multistate Tax Commission (MTC) advanced several items of interest during its annual fall meetings held in Charleston, South Carolina, this week, including the creation of a new committee to continue gathering support for...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Australian Tax Update - October 2015

The Chevron decision provides critically important guidance on both the 'old' (Division 13) and 'new' (Subdivision 815-A) transfer pricing laws in Australia. While not dealing specifically with Subdivisions 815-B to D, the...more

Managing The Changing Tax Landscape: The OECD’s BEPS Recommendations Will Impact Every Multinational

The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that...more

The EC Challenge on Tax Rulings. Why it’s Important that Your Business Acts Now in Relation to EU Challenges to Tax Rulings

21 October 2015: Following state aid investigations, the European Commission has ordered Luxembourg and the Netherlands to recover unpaid taxes of €20-30m from each of Fiat and Starbucks. The Commission has confirmed that...more

European Commission adopts first two decisions in EU tax probe in push for corporate tax reform

On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and...more

The European Commission’s New Pandora’s Box – Reopening Final Tax Rulings as a Form of “State Aid”

In Short - The European Commission (Commission) has adopted a decision on 21 October 2015 on the tax rulings – also referred to as “comfort letters” – granted by Luxembourg to Fiat Finance and Trade (FFT) and by The...more

EU Prohibits "Fiscal Aid"

The European Commission has ruled that two decisions made by national tax authorities artificially reduced the tax burden on the companies involved. ...more

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. ...more

Tax Policy Update

After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory...more

Kyiv Tax Newsletter (Ukrainian) - October 2015

Amendments to the State Budget of Ukraine for 2015 - On September 17, 2015 the Verkhovna Rada of Ukraine adopted the Law on Amendments to the Law of Ukraine on State Budget for 2015 No. 704-VII. According to the...more

Kyiv Tax Newsletter - October 2015

Amendments to the State Budget of Ukraine for 2015 - On September 17, 2015 the Verkhovna Rada of Ukraine adopted the Law on Amendments to the Law of Ukraine on State Budget for 2015 No. 704-VII. According to the...more

Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

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