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Australia Reviews International Arrangements that Mischaracterise Australian Activities Connected with the DEMPE of Intangibles
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January 23rd, 2020
The Australian Taxation Office (ATO) announced that it is reviewing international arrangements that mischaracterise Australian activities connected with the development, enhancement, maintenance, protection and exploitation (DEMPE) of intangible assets. Concerns are that these arrangements may be non-arm's length or structured to avoid tax obligations, resulting in inappropriate outcomes for Australian tax purposes.
OECD Tax Officials Discuss Pillar 1 and 2
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January 21st, 2020
The Federation of German Industries (FDI) hosts its annual tax conference, addressing the tax challenges or the digitization of the economy. In this conference, among others OECD tax officials discussed the status of Pillar 1 and 2.
US: Maryland Proposes Digital Advertising Tax
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January 16th, 2020
In the Senate of Maryland, a bill has been introduced that proposes the taxation of digital advertising. If the bill passes, it would be the first digital services tax on gross revenue introduced by any State in the US.
Colombia Sets Transfer Pricing Documentation Requirements for 2020
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January 14th, 2020
The government of Colombia published decree 2345 concerning tax regulations for natural and legal persons for the year 2020. The decree sets out the deadlines for the tax return filing and payment, as well as the deadlines for filing TP documentation.
Dutch Senate adopts Tax Plan 2020
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December 19th, 2019
The Dutch senate approved more than 50 tax measures for individuals and businesses. The measures are part of the Tax Plan 2020.
TPA Global's Matrix on Key Transfer Pricing Issues regarding Treasury Activities
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December 18th, 2019
The UN released an updated draft on financial transactions in April 2019, which in addition to the discussion draft released by OECD in 2018, provides guidance on the disputes in transfer pricing issues. Here we compare the two drafts and advanced domestic practices (i.
ECOFIN Endorses EU Code of Conduct Group Report
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December 17th, 2019
During the Economic and Financial Affairs Council (ECOFIN) meeting a report from the Code of Conduct Group (COCG) was endorsed. Earlier, the Council of the EU published the report that involves the work of the COCG in the second half of 2019.
Turkey Enacts New Law on Digital Services Tax
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December 13th, 2019
Turkey published Law No. 7194 in its Official Gazette. By means of this law, Digital Services Tax, Tax on high-valuable property, and Accommodation Tax have been established. In addition, some amendments and additions have been made in certain articles of Real Estate Tax Law No 1319, Expense Tax Law No 6802, Income Tax Law No 193 and Tax Procedure Law No 213.
Bulgaria Amends Corporate Income Tax Act
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December 10th, 2019
Bulgaria published the law on amendments to its Corporate Income Tax Act in its official state gazette. The amendments were adopted by the 44th National Assembly on November 21, 2019.
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
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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
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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):
Transforming the World of Tax

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