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EU Ministers Fail to Agree on Public CbCR
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December 6th, 2019
The EU Competitiveness Council (COMPET) failed to agree on a directive concerning disclosure of income tax information by large international companies. EU Ministers responsible for industry and the internal market met in Brussels to discuss, among others, Country-by-Country reporting (CbCR).
US: Final and Proposed Regulations Regarding Foreign Tax Credits and Base Erosion and Anti-abuse Tax
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December 3rd, 2019
US Treasury and IRS have issued proposed and final regulations relating to Foreign Tax Credits (FTC) and the Base Erosion and Anti-abuse Tax (BEAT). These are significant international tax provisions of the Tax Cuts and Jobs Act (TCJA).
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
We would like to invite you to join the following webinars,
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Australian Taxation Office Provides Further Draft Guidance for Hybrid Mismatch Rules
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November 27th, 2019
The Australian Taxation Office (ATO) has published draft Taxation Determination TD2019/D12, titled as “ Income tax: is section 951A of the US Internal Revenue Code a provision of a law of a foreign country that corresponds to section 456 or 457 of the Income Tax Assessment Act 1936 for the purpose of subsection 832-130(5) of the Income Tax Assessment Act 1997? ” The draft provides guidance on the application of Australia’s hybrid mismatch rules in relation to the US ‘GILTI rule’.
It outlines why the ATO believes that section 951A of the US Internal Revenue Code (IRC) does not correspond to section 456 and 457 of Australia’s controlled foreign company regime for the purpose of applying Australia’s hybrid mismatch rules.
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.
China Introduces Tax for Cross-border e-Commerce
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November 19th, 2019
China’s State Taxation Administration has announced the introduction of preferential taxation on the total income earned from cross-border e-commerce retail exports by qualified e-commerce enterprises.
The tax will be 4 percent on the total income earned from the exports of retail goods and concerns the cross-border e-commerce retail export enterprises in pilot zones selected by the Chinese government.
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
; posted on
November 14th, 2019
Become a Transfer Pricing Professional with the online study trainer and e-exam: the most unique training package in the world!
The Transfer Pricing Professional online training consists of 2 online courses:.
9 EU Finance Ministers Call For Aviation Tax
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November 12th, 2019
In a joint statement, 9 finance ministers called upon the European Commission to advance a proposal for an EU initiative on aviation pricing. The ministers of Germany, France, Sweden, Italy, Belgium, Luxembourg, Denmark, the Netherlands and Bulgaria stated that aviation is not sufficiently priced when compared to other means of transportation.
CFO's Journey from 'Staying Out Of Trouble' to being 'Fully In Control'
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November 11th, 2019
TPA Global has developed a practical roadmap of 6 steps meant to guide CFOs in their Journey of rising above troubles to reach a situation of full control. These steps are presented in a series of short video clips (3-5 minutes):
Introduction.
Profit Allocation - ‘Formular Approach Versus Traditional Transfer Pricing’
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November 8th, 2019
To determine the proper level of profits in tax jurisdictions is extremely essential for the tax revenues of the hosting countries. The most widely-accepted principle for tax purposes by MNE groups and tax administrations is the arm’s length principle.
EU Code of Conduct Group Recommends Amendments to Tax Blacklist
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November 8th, 2019
The EU Code of Conduct Group (Business Taxation) released a report concerning the EU list of non-cooperative jurisdictions for tax purposes. In this report, the Code of Conduct Group suggests amendments to the Annexes of the EU Council conclusions of March 12, 2019.
Mexico’s Congress Approves Tax Reform 2020
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November 7th, 2019
Mexico’s congress approved, with some adjustments, the package of tax reforms for 2020 that was submitted by Mexico’s president Lopez Obrador on September 8, 2019. The final package now needs to be signed by the president, which is likely to happen shortly.
EU Commission Opens In-Depth State Aid Investigation Into Support Measures Granted By Poland
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November 2nd, 2019
The European Commission announced that it had opened an in-depth investigation to assess whether two support measures with a total value of EUR 39 million granted by Poland in 2012-2013 to a chemical company PCC MCAA Sp. Zo.o (PCC) for investing in a new plant in Poland are in line with EU rules on regional State Aid.
Is The Arm's Lenght Principle Still Valid After The Starbucks And Fiat Judgments?
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October 30th, 2019
Without doubt, the much-awaited judgments of the EU Court in Starbucks and Fiat have created an array of debates, from application of the concept of state aid to tax matters to redesign of transfer pricing concepts. Therefore, we bring to you three experts on the matter, Philip Baker, Hans van den Hurk and Steef Huibregtse, who will seek to answer some of these questions in a webinar and present their view on the judgement and what lies ahead for multinationals in Europe.
EU Pushes for Public Tax Reports Stalls
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October 29th, 2019
The European Parliament has adopted a resolution calling on EU Member States and the Finnish presidency of the Council of the European Union to move forward on public Country-by-Country reporting. The resolution, adopted by 572 votes in favour, 42 against and 21 abstentions.
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.
Colombia Presents New Tax Bill To Congress Following Court Ruling
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October 25th, 2019
Colombia’s Finance Ministry has submitted a tax reform bill to Congress to replace the financing law, which included income tax changes, overturned by the Constitutional Court last week.
The Constitutional Court decision .
CbCR, ICAP And CRS - Taxpayer’s Rights In An Age Of Data Collection
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October 23rd, 2019
The collection of information by tax authorities entails a correlative taxpayers’ right to access such information and correct its inaccuracies, along with an obligation for tax authorities to protect its confidentiality to the fullest extent possible from any form of misuse, either by tax administration officials or by third parties. However, while the legislative bodies (both national and international) have been increasingly imposing additional compliance burdens on multinational corporations, little has been said about the rights of these multinational taxpayers in this dynamic context.
Transforming the World of Tax

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