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CIAT Develops Risk Model For The Selection Of Transfer Pricing Audit Cases In Ecuador
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August 7th, 2019
The Inter-America Center of Tax Administration (CIAT) announced the publication of a document entitled: "Structuring of a transfer pricing risk model in Ecuador" on the structuring of a transfer pricing risk model in Ecuador, which was developed by Ecuador's tax administration (SRI) with the coordinated support of CIAT, the UN, the German Society of International Cooperation (GIZ), and the Mexican tax administration service (SAT).
The structure of Ecuador’s risk model .
Canada Opens Consultation on Tax Base Avoidance Measures To Strengthen Transfer Pricing Rule
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August 3rd, 2019
The Canadian Department of Finance has opened a consultation on proposed tax measures that would improve transfer pricing rules, counter tax base erosion via foreign affiliate dumping, and apply withholding tax to cross-border share lending arrangements.
Legislative proposals .
International Tax Review’s 19th annual Global Transfer Pricing Forum
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July 31st, 2019
International Tax Review’s Global Transfer Pricing Forum 2019, Amsterdam (NL)
This event gathers in-house transfer pricing professionals, leading advisers and senior policymakers to discuss the insights of the current TP environment and exchange valuable experiences in managing risks and exploring opportunities. The Forum aims to facilitate free and transparent debate on significant issues such as the OECD’s taxation of the digital economy, developments in tax technology and the rise in TP disputes.
Brazil Offers Tax Incentives for Companies Invest Through 'Infrastructure Debentures' In Oil And Gas Sectors
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July 30th, 2019
The Brazilian Ministry of Mines and Energy published a regulation under which companies in the oil and gas sector may claim tax incentives for foreign investments, made in priority investment projects in oil, natural gas and biofuel infrastructure areas through debentures issued by Brazilian entities established as corporations.
Details .
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.
Switzerland To Lose Signicant Tax Revenue Due To International Tax Reforms
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July 23rd, 2019
Swiss Treasury claimed that the country could lose up to CHF10 billion of tax revenues which includes cantons and municipalities taxation. The lose caused by changes in corporate taxation rules to capture a larger share of taxes of multinationals based in tax-friendly destinations like Switzerland.
EU Advisory Body Proposes a Method To Allocate Residual Profits From Marketing Intangible
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July 19th, 2019
The EU Advisory Body has proposed a method to allocate residual profits from marketing intangibles with a four-factor formula as a way to adapt global tax rules for the digital age. The European Economic and Social Committee ( EESC ) adopted an opinion about taxation of the digital economy, noting that any changes on the allocation of taxing rights among countries should be coordinated globally, in order to harness the benefits of globalization.
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.
French Parliament Approves The Reduction of Corporate Income Tax Rate
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July 16th, 2019
The French parliament approved legislation shifting the trajectory of the reduction in the corporate income tax rate that already enacted in the 2018 finance law.
Corporate income tax measures .
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.
India’s Budget 2019-20: Expanding Lower Corporate Rate, Increasing Tax Rate For Higher Earners
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July 9th, 2019
India's Union Budget for 2019-20 was presented to Parliament, proposing changes to the tax laws starting 1 April 2019. This Finance Bill follows the interim budget announcement in February 2019 which was made ahead of the recent national elections.
Tax Technology - Big Tax Brother is watching you
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July 9th, 2019
Tax authorities are increasingly relying on technology for data gathering, exchange of information and analytics. Current digital systems can even provide real-time tax collections, re-conciliations and assessments.
The Next Generation of Benchmarking
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July 8th, 2019
Value Chain Analysis (VCA) was incorporated into the regulations following the OECD/G20 BEPS initiative (BEPS Actions 8 - 10), and subsequently, embedded in the OECD Transfer Pricing Guidelines 2017.
The importance of VCA in the OECD Transfer Pricing Guidelines, 2017, is revealed in their collective title: “ Aligning Transfer Pricing Outcomes with Value Creation ”.
Australian Global Resources Company To Pay $175 Million In Tax Dispute
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July 4th, 2019
BHP Group, the third-largest producer of the steel-making ingredient agrees to pay AUD250M (U$175M) to State Australia (Western) tax authority to end a dispute over royalties paid on iron ore shipments sold through its Singapore marketing hub.
The accusations of having underpaid iron ore royalties .
The UK to Adopt EU Double Taxation Dispute Resolution Regulations
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July 4th, 2019
UK HMRC has launched a technical consultation on the Draft Double Taxation Dispute Resolution (EU) Regulations 2019. The Regulations are for the implementation of Council Directive on tax dispute resolution mechanisms in the European Union.
Dutch Cabinet Submits New Bill Against Tax Avoidance
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July 4th, 2019
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2).
Implementation of ATAD2: Hybrid mismatches .
We Are Hiring - Junior Personal Assistant (part-time)
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July 2nd, 2019
TPA Global HQ in Amsterdam is looking for a Junior Personal Assistant (part-time) to join our team.
Are you pro-active, service-oriented, and eager to learn and want to grow as a PA? .
Taiwan Releases Guidance On The Application Of The Beneficial Owner To Be Aligned With OECD Approach
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July 2nd, 2019
Taiwan’s Ministry of Finance (MOF) released guidance to clarify the application of the term “beneficial owner” (BO) for tax treaty purposes. The Guidance aims to provide greater clarity for taxpayers as it specifies the situations where BO status will be granted or denied and aligns Taiwan’s position with the OECD Model Tax Convention Commentary, MOF practices and approaches taken by other countries.
EU Notes Launch of New Tax Dispute Resolution Mechanism
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July 2nd, 2019
As from June 2019, new EU rules come into force to ensure that businesses and citizens can resolve disputes related to the interpretation of tax treaties more swiftly and effectively between the Member States, making daily life easier and offering much more tax certainty for businesses and individuals experiencing double taxation issues.
Resolution of tax disputes in the European Union .
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