Transfer Pricing Blog
BEPS, The Latest OECD Release: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
The OECD has provided guidance on the transfer pricing documentation structure comprising of the following 3 documents: Master file – Providing a general overview if the MNE and its business activities ( in general applicable to all entities within the MNE); Local...
Can one rely on APA in US? Eation Corp is challenging the Internal Revenue Service in U.S. Tax Court
Eation Corp is challenging the Internal Revenue Service in U.S. Tax Court, arguing that the agency broke agreements dealing with how the company moves assets and money across international borders. Eaton is contesting a $75 million tax bill that the IRS imposed on the...
Canadian Supreme Court decision on GlaxoSmithKline’s Transfer Pricing Case
GlaxoSmithKline ($GSK) prevailed in a tax challenge from the Canadian government. The U.K.-based drugmaker won backing from the country’s highest court, in a much-watched battle over using transfer pricing to cut its tax bill. At issue in the case were...
UN session on the Practical Manual on Transfer Pricing for Developing Countries
In accordance with ECOSOC decision 2012/255 of 23 July 2012, the eighth annual session of the Committee of Experts on International Cooperation in Tax Matters will be held from 15 to 19 October 2012 at the Palais des Nations in Geneva. The main focus of the session...
Russia: Timing of the procedure of an APA process has been determined
Based on the order № ММВ-7-13/182@ (registered on 23.04.2012 under № 23929) dated 26.03.2012 The Russian Tax administration approved a set of documents to be used by the Russian Tax authorities for review of the applications and set the grounds for the procedure and...
Meeting at OECD’s first Global Forum on Transfer Pricing
Meeting at OECD’s first Global Forum on Transfer Pricing, tax officials from 90 countries agreed on the need to simplify transfer pricing rules, strengthen the guidelines on intangible issues and improve the efficiency of dispute resolution. Delegates agreed that...
Will OECD adjust to reality?
“Transfer Pricing: Will the OECD adjust to Reality?” an interesting article released ahead to the Transfer Pricing seminar on 13-15th June, 2012 in Helsinki from Senior Advisor to Tax Justice Network David Spencer. The article discusses how the OECD Transfer Pricing...
Dealing Effectively with the Challenges of Transfer Pricing
This OECD report addresses the practical administration of transfer pricing programmes by tax administrations. Technical analysis of how transfer prices should be computed in accordance with the arm’s length principle is outside the scope of this report. Instead the...
OECD Discussion Draft on Transfer Pricing Aspects of Intangible Assets
After urging the OECD Working Party No6 the discussion draft on transfer pricing aspects of intangible assets was published some time ahead of the expected 2013 release date. Topics include identifying intangibles, identification of parties entitled to intangible...