News & Analysis as of

Organization for Economic Co-operation and Development Multinationals Transfer Pricing

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald

In the new episode of our tax podcast, “GILTI Conscience,” EY’s Michael McDonald discusses whether the OECD’s DEMPE transfer pricing guidelines are being properly interpreted, including whether some jurisdictions are placing...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis

In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Jones Day

JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision

Jones Day on

The Glencore decision is a landmark ruling on the application of Australia's transfer pricing rules governing transactions within multinational groups. These rules seek to ensure that tax is not avoided as a result of...more

Womble Bond Dickinson

US Treasury Leadership Gives Direction to the OECD Digital Tax Project in January 29 Note

Womble Bond Dickinson on

OECD Note is Prelude to March Public Consultation on Global Tax Solutions - With the release January 29, 2019 of an important tax policy note (the “Note”), the Organization for Economic Cooperation and Development (the...more

Jones Day

Australian Senate Economics Committee Hands Down Report on Corporate Tax Avoidance

Jones Day on

The Commonwealth Senate Economics Committee (a standing committee composed by members of the upper house of Parliament) handed down its long-awaited final report on corporate tax avoidance in Australia. The final report is...more

Jones Day

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - April 2017

McDermott Will & Emery on

Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

Hogan Lovells

Base erosion and profit shifting - new regulations

Hogan Lovells on

International tax issues have never been more prevalent than in today's integrated economic environment and international markets. As the world becomes increasingly globalised and cross-border activities become the norm, the...more

Proskauer - Tax Talks

New Public Country-by-Country Reporting of Financial Information Proposed by European Commission

Proskauer - Tax Talks on

Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing...more

McGuireWoods LLP

Tax Policy Update

McGuireWoods LLP on

After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to do a bit of soul searching and reflect on the future of a party left in...more

Bennett Jones LLP

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

Bennett Jones LLP on

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

Bennett Jones LLP

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

Bennett Jones LLP on

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

Bennett Jones LLP

International Tax & Transfer Pricing Strategies in the Crosshairs

Bennett Jones LLP on

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

K&L Gates LLP

Government Releases New Transfer Pricing Measures to Attack Multinationals

K&L Gates LLP on

On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied. The legislation will come...more

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