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April 26th, 2016
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Are You Ready For Your FY 2016 Value Chain Analysis To Be Shared With Your Tax Inspector In China?
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June 26th, 2017
2016财年的价值链分析您准备好了吗?
Although, the arm’s length principle in essence still is the driving force for analyzing intercompany transactions, how we apply that has changed in important ways. We are now required to follow a holistic approach in the form of Value Chain Analysis (VCA) for the multinational group before we could firmly say what arm’s profits each entity in the group should be earning.
Swiss Council Adopts Dispatch On AEOI With 41 States And Territories
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June 21st, 2017
The Federal Council adopted the dispatch on the introduction of the automatic exchange of financial account information (AEOI) with 41 states and territories. At the same time, Swiss banks informed they will keep a close watch on data protection measures taken by countries.
PoEM Rules - The Indian Government Issues A Draft Notification For Comments
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June 19th, 2017
Recently the government vide draft notification dated 15th June, 2017 provided exceptions, modification, and adoption in respect to PoEM rules on which comments and suggestions from the general public are invited.
The concept of Place of Effective Management in India (“PoEM”) was introduced in Finance Act, 2015.
Hong Kong To Exchange Information (AEOI) With Indonesia
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June 17th, 2017
Hong Kong has signed an agreement with Indonesia for conducting automatic exchange of financial account information in tax matters (AEOI). Following the agreement with Indonesia, Hong Kong now has 13 AEOI partners.
Indonesia Reaches Tax Settlement With Google
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June 15th, 2017
On June 13, Indonesian Finance Minister Sri Mulyani Indrawati informed that Indonesia has reached a tax settlement with Alphabet Inc's Google for 2016. This follows an ongoing dispute over allegations that Google avoided paying tax for its advertisement activities.
PANA To Address Financial Intelligence Units And The "Russian Laundromat Case"
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June 15th, 2017
On June 21, the Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) will hold a meeting on "Financial Intelligence Units (FIUs) – Ins and Outs, and the Russian Laundromat case".
Bank records
OECD Requests Feedback On Dispute Resolution Peer Reviews
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June 13th, 2017
The OECD informed it invites taxpayers to answer questions regarding specific issues related to access to the Mutual Agreement Procedure (MAP), clarity and availability of MAP guidance and the timely implementation of MAP agreements for the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain.
Background: MAP
EU JURI and PANA Committee To Hold Hearing On The Protection Of Whistleblowers
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June 13th, 2017
On June 21, the Members of the EU Committee on Legal Affairs (JURI) and PANA Committee will hold a hearing with experts on legitimate measures to protect whistle-blowers acting in the public interest when disclosing the confidential information of companies and public bodies.
Protection for whistleblowers
Members of European Parliament Adopt Public Cbc Reporting With A "Safeguard Clause"
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June 13th, 2017
On June 12, MEPs from the economic affairs and legal affairs committees voted for a public Country-by-Country (CbC) reporting draft directive implementing a 'safeguard clause'. The clause will allow increased tax transparency but ensure no disruption in fair competition by preventing sensitive information to be shared publicly.
Goods & Service Tax (GST) - A True Game Changer For Tax Efficiency In India
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June 13th, 2017
Goods & Service tax (GST) is a land mark change in the way business is done in India.
GST in the current form has tried to organize the highly fluid space of Indirect taxes which are currently being levied on supply chain both by the central union government and the state government.
Tax Technology Event 2017 - From ‘Staying Out Of Trouble’ To ‘Being In Control’
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June 12th, 2017
This workshop is organized to assist businesses in finding their way through the world of tax technology solutions.
In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden.
Cayman Islands Committed to BEPS Because Of Reputational Reasons
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June 9th, 2017
On June 7, over 70 countries and jurisdictions have signed, or formally expressed their intention to sign, an innovative multilateral convention. According to former Minister for Cayman's Financial Services Wayne Panton, the effects of the BEPS project on Cayman are relatively “benign,” but the government committed to the initiative “for reputational reasons,” Cayman Compass reported.
Eight Countries Discuss Cooperation In Risk Assessment
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June 9th, 2017
The OECD International Tax Conference sponsored by the OECD, USCIB, and BIAC was hosted in Washington, DC. The annual conference allowed the USA business community to interact with key representatives from the OECD Tax Officials.
U.S. and South Africa to Exchange CbC Reports
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June 6th, 2017
On June 5, the South African Revenue Service (SARS) released the text of an arrangement between the United States of America and the Republic of South Africa on the exchange of Country-by-Country (CbC) Reports.
Exchange of Country-by-Country Reports
Multinationals Alter Tax Plans Over U.S. Tax Reform
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June 6th, 2017
A new research provided by Taxand that is based on 136 interviews with financial officers and tax directors concluded that more than half of multinationals have altered their tax plans, or delayed decisions, due to the tax reforms in the U.S.
HMRC Carried Out Over 360 Transfer Pricing Reviews
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June 6th, 2017
According to research from the law firm Pinsent Masons, HMRC launched 362 reviews into business transfer pricing in 2015/16. The amount potentially under dispute reached £3.
Thailand Joins The Inclusive Framework On BEPS And Participates In First Joint Programme For The Implementation Of International Tax Standards
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June 4th, 2017
Thailand has become the 98th jurisdiction to join the Inclusive Framework on BEPS ("IF") and will participate on an equal footing with all other IF members at the next plenary meeting of the IF that will be held on 21-22 June 2017 in Noordwijk, the Netherlands.
The IF was established in January 2016, after the G20 Leaders urged the timely implementation of the BEPS package released in October 2015 and called on the OECD to develop a more inclusive framework with the involvement of interested non-G20 countries and jurisdictions, including developing economies.
South Africa - Draft Notice To Submit CbC, Master File And Local File Returns
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June 2nd, 2017
On 2 June 2017, the South African Revenue Service (“SARS”) has published a draft public notice requiring the submission of country-by-country (“CbC”), master file and local file returns. This marks an important step towards the finalisation of South Africa’s transfer pricing documentation requirements.
PANA Committee Meets EC President Juncker
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June 1st, 2017
On May 30, The PANA committee held a hearing with European Commission President Jean-Claude Juncker, stating that a draft law that targets accountants and lawyers running tax-avoidance schemes will be made available before the end of June. The EC President was also accused of helping tax avoidance schemes during his period of Prime Minister and Finance Minister of Luxembourg.
Rocha Andrade Defends Legality Of Madeira’s Free Trade Zone
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June 1st, 2017
On May 30, the European Parliament held a hearing with Fernando Rocha Andrade, the Portuguese Secretary of State of Tax Affairs, addressing Portugal’s approach in the fight against money-laundering, tax evasion and tax avoidance. Andrade had to defend the legality of Madeira’s free trade zone arguing it functions within EU rules.
CJEU - Question Dividend Withholding Tax To Non-Dutch Investment Funds
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May 31st, 2017
The Official Journal of the European Union published two requests for preliminary rulings of the Court of Justice of the European Union (CJEU). The requests question rejection of investment funds established outside the Netherlands on the ground that it is not subject to an obligation to withhold Netherlands dividend tax.
EU Council Adopts Directive On Hybrid Mismatches With Third Countries (ATAD2)
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May 31st, 2017
The EU Council adopted the rules to close down hybrid mismatches with the tax systems of third countries (ATAD 2), which aims to prevent corporate tax avoidance and contributes to the implementation of OECD's base erosion and profit shifting (BEPS) measures.
Hybrid Mismatch Arrangements
India: Pharma Companies Questioned Over Transfer Of IP Assets To Offshore Subsidiaries
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May 31st, 2017
Reserve Bank of India is questioning pharma companies operating in India over the transfer of their intellectual property (IP) assets to offshore subsidiaries. The central bank is looking at ways the foreign subsidiaries have raised loans abroad to pay for the intellectual property assets transferred to them, the Economic Times reported.
LATAM Country Summaries Update (2)
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May 31st, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates
OECD releases peer review document for assessment of the BEPS Action 6 minimum standard
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May 29th, 2017
Today the OECD released the key document, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of the Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances.
The Action 6 minimum standard is one of the four BEPS minimum standards.
USA Country Summary Update
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May 29th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates
EU Council Agrees Its Position On Dispute Resolution Procedures
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May 29th, 2017
The EU Council agreed on a new system for resolving double taxation disputes within the EU. The Council reached compromise on the scope of the directive, 'independent persons of standing' and standing committee.
BEPS Project Potentially Harmful To Asset Management Industry
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May 29th, 2017
During a panel discussion at the Guernsey Funds Forum in London, tax experts warned that the asset management industry could be harmed by the proposed Base Erosion and Profit Shifting (BEPS) project. The experts warned that the rules ignore how the asset management industry works and that every country has its own version of what BEPS really means.
OECD Seeks Feedback on Hard-To-Value Intangibles Guidance
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May 23rd, 2017
OECD invited interested stakeholders for public comments on a discussion draft which provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.
Background: Hard-to-value Intangibles
US to Consult Destination-Based Taxation And Border Adjustments
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May 23rd, 2017
The House Committee on Ways and Means published a document prepared by the staff of the Joint Committee on Taxation that provides an overview and analysis of destination-based taxation and border adjustments. The document has been published ahead of a public hearing on border adjustments and international tax reform that takes place on May 23.
News
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April 26th, 2016
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