The operative, but not exclusive, article of law in France that currently governs transfer pricing is Article 57 of the French Tax Code ("FTC"), entitling French Tax Authorities ("FTA") to reassess related transactions whose conditions deviate from what independent parties would have agreed under...
The global tax environment is rapidly changing. Tax strategies, which have been legal and common for many years, are increasingly regarded as unacceptable. The public perception that corporates artificially shift earnings to low tax jurisdictions and default on their "social contract" has...
Recent international tax developments in Asia reflect the growing focus on transfer pricing, in tandem with global developments. This summary highlights recent key transfer pricing policy announcements in the region and discusses the potential local impact of country-by-country reporting (CBCR)...
As part of Base Erosion and Profit Shifting Project (BEPS), OECD has recently issued a publication on transfer pricing aspects of intangibles. The topic of the publication is important, as during the past decades many countries have witnessed a shift from the capital intensive economy to the economy...
On 25 March 2014, Hong Kong signed a standalone tax information exchange agreement (TIEA) with the US for the enforcement and assessment of taxes. This is the first TIEA signed by Hong Kong after the legal framework for entering into TIEAs with other jurisdictions was put in place last July.
The Dutch approach to the arm's length principle has always kept pace with the evolving international interpretation, and arguably in certain aspects has even been ahead of its time. The OECD guidance around alignment between the actual controlling of risks with the contractual division of risks, as...
It has been more than seven years since the Inland Revenue Authority of Singapore (IRAS) released the Singapore Transfer Pricing Guidelines (Guidelines). The key developments in recent times are an increase in the focus of the IRAS on transfer pricing compliance and the use of Advance Pricing...