Transfer Pricing

News & Analysis as of

Australian Taxation Office issues new Practice Statement on Advance Pricing Arrangements

The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate...more

Tax Court Overturns Important Transfer Pricing Regulations

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under code section 482 that says taxpayers have to take into...more

Ukraine: New Rules for Advance Pricing Agreements Adopted

On 25 July 2015 the Cabinet of Ministers of Ukraine published an order on the conclusion of advance pricing agreements ("APA") in respect of controlled transactions for transfer pricing purposes* ("the APA Order"). The APA...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

Focus on Tax Controversy - Summer 2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

WCO publishes guide to customs valuation and transfer pricing

The challenges faced by multinational enterprises (MNEs) in navigating the interface of transfer pricing and customs valuation rules is not a new phenomenon. However, due to a marked increase in recent years of the number of...more

24 Months Through the Crystal Ball: Emerging Trends in State and Local Taxation (Part II)

This is the second of two articles guiding taxpayers through the next 24 months of state taxation’s turbulent waters. In this article, we address three additional significant trends. Corporate Income Taxation: Heat and...more

Kyiv Tax Newsletter (Ukrainian)

Cancellation of the Military Tax on Currency Exchange Transactions - On 12 May 2015 the Verkhovna Rada of Ukraine adopted the Law of Ukraine “On Amendments to the Tax Code of Ukraine in Respect of the Military Tax” which...more

Kyiv Tax Newsletter

Cancellation of the Military Tax on Currency Exchange Transactions - On 12 May 2015 the Verkhovna Rada of Ukraine adopted the Law of Ukraine “On Amendments to the Tax Code of Ukraine in Respect of the Military Tax” which...more

International Tax Grows Up: The Tax Section at 75, Subpart F at 53, and the Foreign Tax Credit at 97

As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more

Alas, the MTC Executive Committee Approves Its Transfer Pricing Program Design

After nearly a year of planning, the Multistate Tax Commission Executive Committee today approved the Arm’s-Length Adjustment Services Advisory Group (the Group) Final Program Design. The following six states have agreed to...more

District of Columbia’s Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking Two Bites of the Same Apple

In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is...more

Focus on Tax Controversy - Spring 2015

In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more

"Appeals Court Reverses IRS-Favorable Tax Court Decision in BMC Software"

On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more

Transfer Pricing Customs Duty Refund Applications – Let’s Do it Right

The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments having the effect...more

Recent Developments - Australian Transfer Pricing (TP) Rules: Time To Step Up

With the Australian Taxation Office's (ATO) escalating focus on international profit shifting, it is essential for multinational taxpayers (MNEs) to properly understand the new Australian Transfer Pricing (TP) rules, assess...more

Let the Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state...more

MTC Inches Closer to Developing Its Transfer Pricing Program

The Arm’s Length Adjustment Service Advisory Group (ALAS) of the Multistate Tax Commission (MTC) continued its transfer pricing effort with a teleconference today to discuss its training and implementation program. This...more

Transfer pricing: US readies adoption of OECD's country-by-country reporting requirement – implications for US taxpayers

The US Treasury Department has announced plans to implement a country-by-country (CbC) reporting requirement starting for fiscal years beginning in 2016 as set out in the guidance issued by the Organisation for Economic...more

India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

French Finance Act for 2015 and Amending Finance Act for 2014: Key Tax Measures for Corporations

The French Finance Act for 2015 and Amending Finance Act for 2014 were enacted on December 30, 2014 (the “Acts”). The Acts introduce a new penalty for failure to comply with French transfer pricing requirements, and a...more

MTC Puts Designs on Increasing State Transfer Pricing Revenues

This past December, the Multistate Tax Commission’s (MTC) transfer pricing advisory committee and its project facilitator Dan Bucks recommended what it calls the “preliminary design” approach for a proposed Arm’s Length...more

A swift look at the OECD discussion drafts on BEPS plus one chart setting out timelines

During the short days before Christmas, when most of us were busy closing transactions or making last-minute year-end reviews to financials, the OECD released several BEPS (Base Erosion and Profit Shifting) discussion drafts,...more

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