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Corporate Taxes Organization for Economic Co-operation and Development Transfer Pricing

Freeman Law

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

Freeman Law on

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

Hogan Lovells

Applying an arm’s length comparator to intra-group debt: the role of third-party covenants

Hogan Lovells on

When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more

Skadden, Arps, Slate, Meagher & Flom LLP

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Jones Day

JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision

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The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more

Proskauer Rose LLP

UK Tax Round Up - December 2020

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COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Freeman Law

International Tax Treaty: Australia

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Quick Summary. Located “down under” in the Southern Hemisphere and covering the Indian and Pacific Oceans, Australia consists of a mainland continent, the island of Tasmania, and several smaller islands. Australia comprises...more

Jones Day

EU Court Overturns Commission Decision in Landmark Apple Tax Case

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The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question gave rise to a selective advantage under EU...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

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UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Eversheds Sutherland (US) LLP

LB&I announces new campaigns – Related-party service companies, offshore private banking and loose-filed Forms 5471

On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

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OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more

Jones Day

Australian Senate Economics Committee Hands Down Report on Corporate Tax Avoidance

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The Commonwealth Senate Economics Committee (a standing committee composed by members of the upper house of Parliament) handed down its long-awaited final report on corporate tax avoidance in Australia. The final report is...more

Akin Gump Strauss Hauer & Feld LLP

European Court of Justice: Intercompany Pricing Cannot Be Used For EU Import/Customs Purposes If Subject to Adjustments

• A recent judgment of the European Court of Justice for bars the use of intercompany transfer prices for EU imports and EU customs duty purposes if (as is commonly the case) these are subject to retroactive adjustments. ...more

Jones Day

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

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As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

Proskauer Rose LLP

UK Tax Round Up - September 2017

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UK Tax News and Developments - Finance (No 2) Bill 2017 - The second Finance Bill of 2017, known as Finance (No 2) Bill 2017, has now been published. As expected, this contains most of the provisions which were dropped from...more

Bennett Jones LLP

Is Your Customs Compliance BEPS Ready?

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2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

Hogan Lovells

Base erosion and profit shifting - new regulations

Hogan Lovells on

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

Bennett Jones LLP

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

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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

Bennett Jones LLP

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

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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

Skadden, Arps, Slate, Meagher & Flom LLP

"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

Dechert LLP

Transfer Pricing: Major Developments for Certain French Companies Engaging in Transactions with Related Entities

Dechert LLP on

The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies. New Provisions of French Law - Provisions Already Adopted - Within the...more

Bennett Jones LLP

International Tax & Transfer Pricing Strategies in the Crosshairs

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The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

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