Category: Tax Planning
Enhanced transfer pricing regime amidst the pandemic
Globally, the coronavirus disease 2019 (Covid-19) pandemic is requiring governments to design and implement strategies to cope with the deepening impact of the virus. They are introducing measures to cushion the blow from the economic downturn, such as drawing from reserves and intensifying tax collection efforts. As entire countries and… – Continue reading
Ecuador publishes new transfer pricing guidance
On the 1st of July 2020, Ecuador's tax authority communicated its new transfer pricing laws. ... - Continue reading
Public input sought on Brazil, OECD transfer pricing harmonization
Brazil set out in the direction of tax reform. ... - Continue reading
Canada: Don’t Let Your Dream Vacation Home Become A Tax Nightmare
Renting your foreign property may require you to disclose information to the Canada Revenue Agency (the "CRA"). A Foreign Income Verification Statement is required to be filed with the CRA where the adjusted cost base of the property exceeds CDN $100,000. ... - Continue reading
EU to launch tax observatory
The EU’s awareness of the relevance of tax policy is clear. On 6 July, the European Commission called for proposals for the creation of an EU tax observatory. This follows the adoption of the Commission Decision on the financing of the preparatory action EU Tax Observatory – Capacity building to support Union policy making in the area of taxation and the adoption of the annual work programme for 2020 on 16 June. ... - Continue reading
The Netherlands’ new DAC6 requirements: what multinationals need to know
Multinationals with European Union operations need to be aware of the DAC6 reporting obligations, especially since there are situations in which multinationals will be required to report cross-border arrangements with local tax authorities. ... - Continue reading
OECD says U.S. still committed to global digital tax talks
OECD informs that the United States are still open to a discussion on digital tax despite asking for a pause due to more pressing matters. ... - Continue reading
Australia transfer pricing guidance addresses COVID-19 impact
Transfer pricing after COVID-19 in Australia. ... - Continue reading
Higher tax bill for Cyprus businesses after new law
Cyprus is aiming to better tackle tax avoidance by companies through a new legislation. The latter mainly addresses base erosion and profit shifting. ... - Continue reading
Challenges for Transfer Pricing in an Economic Downturn
It is no surprise to anyone that we are now enterring a recession due to the economic chaos caused by the COVID-19. Consequently, countries all over the world have been adjusting their tax laws to the unprecedented turn of events. In this article, we will focus on transfer pricing laws. ... - Continue reading
Bringing clarity to documenting intercompany financing during a pandemic
Light upon intercompany financing transactions in the midst of the current pandemic. ... - Continue reading
Whirlpool’s maquiladora: the Mexican transfer pricing perspective
A discussion of the court case of Whirlpool Financial Corporation vs the IRS with respect to a transfer pricing perspective. ... - Continue reading
India: Transfer Pricing And COVID-19 — Repercussions, Re-Evaluation And Way Forward
Here is a discussion on multinational enterprises (MNEs) and their possible treatment of the aftermath of the COVID-19 pandemic. ... - Continue reading
Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches
Guidance on transfer pricing transactions during the unprecedented crisis. ... - Continue reading
Italy’s Supreme Court rules on VAT treatment of intercompany management fees
Highlights on a recent court case in Italy regarding transfer pricing. ... - Continue reading
German finance ministry clarifies transfer pricing proposal
"No price-setting approach", confirms the German Finance Ministry. ... - Continue reading
Ireland transfer guidance addresses claims for unilateral tax relief
Lights upon Ireland's unilateral tax relief in relation to the double taxation agreement. ... - Continue reading
OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance
Disagreement registered around the 'Pillar One' of the OECD. ... - Continue reading
EU Commission to investigate whether Netherlands granted IKEA subsidiary State aid by approving tax deductions
The European Commission to investigate into Inter IKEA systems' tax treatment for a possible breach of EU State Aid rules. ... - Continue reading
New Poland transfer pricing risk assessment tool released in interactive format
Poland launches a new transfer pricing risk assessment tool and it's an interactive version. ... - Continue reading
Finland transfer pricing rules analyzed in landmark court rulings
This article focuses on two tax cases revolving around transfer pricing and their respective treatments. ... - Continue reading
COVID-19 and the future of Pillar one
2020 started with a focus on reformed tax laws concerning transfer pricing and the implementation of Pillar one from the OECD. This article delves further into the matter to bring more clarifications. ... - Continue reading
New South Korea transfer pricing and diverted profits tax laws enter into effect
A few information on amended tax laws for South Korea as from 2020. ... - Continue reading
Denmark extends all filing deadlines, including those for transfer pricing documentation
Extension until 1st September 2020 for deadlines, and it won't even require an application. ... - Continue reading
Nigeria’s Tax Appeal Tribunal decides Prime Plastichem transfer pricing case
A first transfer pricing case in Nigeria offers a glimpse of the treatment of the latter. ... - Continue reading
Poland issues controversial transfer pricing risk assessment rules
New transfer pricing laws issued in Poland might not be too pleasant to multinationals' ears. Read on to know more. ... - Continue reading
India Budget 2020: The key takeaways
Here are some important tax proposals for India's 2020 Budget. ... - Continue reading
The final OECD transfer pricing guidelines for financial transactions: what has changed?
Amendments to transfer pricing laws have been disclosed on 11 February 2020. ... - Continue reading
Spain to scrutinize taxpayers’ transfer pricing positions
Spain focuses on transfer pricing. ... - Continue reading
United States: The OECD Unified Approach Marches (Stumbles?) Forward
The OECD Secretariat proposed the Unified Approach in October 2019 to address the tax challenges arising from the digitalization of the economy. ... - Continue reading
Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere
The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading
Malta: Tax Transparency For Tax Advisors: The Mandatory Disclosure Rules – No More Hiding
The main aim remains linked to curbing tax evasion and avoidance through capturing aggressive tax planning schemes.
... - Continue readingCountries launch review of country-by-country reporting framework for multinational groups
An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.... - Continue reading
Puerto Rico changes income tax law for intercompany charges
Puerto Rico has amended its income tax rules to allow taxpayers to fully deduct intercompany expenses if taxpayers file a transfer pricing study with their income tax return, due April 15, 2020, if not extended. ... - Continue reading
Dominican Republic updates transfer pricing documentation thresholds, tax haven list
What's new about Dominican Republic's tax laws? Here's more. ... - Continue reading
Denmark court applies broad interpretation of transfer pricing law
More on the new Danish transfer pricing legislation. ... - Continue reading
Vietnam issues Draft Pronouncement on Tax Administration, Transfer Pricing, Minimum Basic Wage and Personal Income Tax
The Vietnam Ministry of Finance has issued the draft pronouncement amending certain tax rulings. Some of the main aspects of the draft include: ... - Continue reading
Heineken Vietnam pays $39.7 mln in back taxes, fines
Heineken Vietnam Brewery has paid VND917.2 billion ($39.7 million) in back taxes and fines for a 2018 transaction. ... - Continue reading
