Global News
Germany and US: Joint Statement on Spontaneous Exchange of CbC Reports
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November 28th, 2019
In light of the demand for increased international tax transparency, the Competent Authorities of the US and Germany have made a joint statement, concerning the exchange of CbC Reports with respect to fiscal years of MNE Groups commencing on or after January 1, 2018 and before January 1,2019.
The governments of the countries are negotiating on an intergovernmental agreement and a competent authority arrangement to allow for the automatic exchange of CbC Reports.
TPA Global Webinars - Let's Talk Business!
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November 28th, 2019
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OECD’s Digital Tax Plan Would Raise Little Revenue
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November 21st, 2019
The French Council of Economic Analysis concluded in its study on the effects of the proposed global digital tax plans of the OECD that the increase in corporate tax revenues would be small for France, Germany, the US and China. The French Council has an advisory role to the French government and performed a simulation based on the OECD digital tax proposals.
US Court of Appeals for the Ninth Circuit Denies Rehearing in Altera Case
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November 14th, 2019
The United States Court of Appeals for the Ninth Circuit denied a rehearing en banc in the Altera case, which involves the semiconductor company’s dispute with the IRS over whether stock-based compensation should be included in cost-sharing agreement intangible development costs.
During the 2004-2007 taxable years, Altera shared certain costs with one of its foreign subsidiaries pursuant to a research and development cost-sharing agreement.
Become A Transfer Pricing Professional With The Online Study Trainer And E-Exam
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November 14th, 2019
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The Transfer Pricing Professional online training consists of 2 online courses:.
OECD - Public consultation meeting on the Secretariat Proposal for a "Unified Approach" under Pillar One
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October 28th, 2019
As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS, the OECD is seeking public comments on a Secretariat Proposal for a “Unified Approach” under Pillar One. This public consultation meeting will focus on the key questions identified in the consultation document and issues raised in the written submissions received as part of the consultation process.
UN Updates Manual on Transfer Pricing: Address Comparability and Group Synergies Issue
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October 23rd, 2019
The United Nation's Transfer Pricing subcommittee has sent a new round of proposed changes to the U.N. manual for developing countries, including a revised comparability chapter and new guidance on group synergies and centralized procurement functions.
Guernsey Publishes Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
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October 3rd, 2019
A Briefing Note on the Mandatory Disclosure Rules on Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures (the Note) was published by the Guernsey Revenue Service.
Details of the notes .
US And France Reach A Compromise Over Digital Services Tax
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August 27th, 2019
During a joint press conference with U.S. President Donald Trump, French President Emmanuel Macron announced that a compromise has been reached regarding the French Digital Services Tax (DST), which has been strongly opposed by the U.S. as unfairly targeting U.S. companies.
French tax on tech giants .
Guinea, Namibia and Honduras join the fight against tax evasion
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August 27th, 2019
Guinea, Namibia and Honduras have joined the Global Forum on Transparency and Exchange of Information for Tax Purposes as its 155th, 156th and 157th members. By joining the Global Forum they are announcing their commitment to implement both the international standard of exchange of information on request and the standard on automatic exchange of financial account information .
Ireland To Shift Its Tax Allure To Non Tax Feature After BEPS 2.0, Group Warns
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August 21st, 2019
The Organisation for Economic Cooperation and Development (OECD) announced a new programme of work, which described as BEPS 2.0. It introduces further reforms to the framework for international taxation.
US Ride-Hailing Company Creates a $6.1 Billion Dutch Tax Deduction to Reduce Paying Taxes
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August 13th, 2019
Uber Technologies Inc. created a $6.1 billion Dutch tax deduction that will help the company reduce its global tax bill for years to come. Uber generated the outsized deduction by moving some of its offshore subsidiaries to different countries as a result of new European Union rules governing multinational companies.
International Consortium Of Investigative Journalists Publishes 'Mauritius Leaks' Data
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July 25th, 2019
The International Consortium of Investigative Journalists (ICIJ) has published data on over 200 companies as part of its 'Mauritius Leaks' investigation. The report found that multinational companies abuse the favorable tax treaty of Mauritius to avoid paying taxes.
OECD introduces Analytical Database on Individual Multinationals and Affiliates (ADIMA)
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July 25th, 2019
Multinational Enterprises (MNEs) have been at the forefront of changes in the global economy over the last few decades, as trade and investment barriers have been removed and transportation and communication costs have declined. In a world of global value chains, understanding MNEs – where they are, how they operate, and where they pay taxes – has never been more important.
US Senate Adopts Controversial Exchange Of Information In Their Ratified Protocols To Tax Treaties With Japan, Switzerland and Luxembourg
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July 19th, 2019
The U.S. Senate approved updates of tax treaties with Switzerland, Japan and Luxembourg that had been stalled for years over taxpayer privacy concerns. The updates approved a day after ratifying a similar update of a treaty with Spain.
UN Releases Updated Tax Treaty Manual With Anti-Avoidance Language
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July 11th, 2019
The UN has published a new version of the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries . First published in 1978, the Manual is prepared by the UN’s Committee of Experts on International Cooperation in Tax Matters.
Saint Lucia’s House of Assembly Agrees To Income Tax Amendment (2) Act
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June 27th, 2019
The Government of Saint Lucia announced that its House of Assembly has agreed to the Income Tax Amendment (2) Act. This ensures that an international business company (IBC) would not give any benefit to companies that might violate OECD standards.
US Pharmaceutical Giant Moves Its Headquarter To US from Ireland For Tax Purposes
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June 27th, 2019
AbbVie Inc. and Allergan plc. announce that the companies have entered into a definitive transaction agreement under which AbbVie, headquartered in US, has acquired Allergan on June 24, 2019. By that, one of US's pharmaceutical giants is coming back to the U.
IRS investigates The Transfer Pricing Position Of US Ride-Hailing Company
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June 6th, 2019
Uber Technologies Inc. is being examined by U.S. tax authorities and said that its potential tax charges in a number of key markets could change. The ride-hailing company expects unrecognized tax benefits to be reduced within the next year by at least $141 million.
OECD Releases Workplan On New Rules For Taxing Digital Multinational Enterprises
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June 4th, 2019
The Organization for Economic Co-operation and Development (OECD) released its document Program of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy.
Following a Policy Note released in January 2019, the Inclusive Framework has continued to develop the proposals presented earlier under the two Pillars used to organize the ongoing work.

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