Expert Guides - Transfer Pricing

“Independent transactions influenced by special relationship” and clarifications of other (new) concepts in the recently introduced revised transfer pricing regulations in Indonesia

The Ministry of Finance (“MoF”) recently issued MoF Regulation No.22/PMK.03/2020 (“PMK 22/2020) concerning advance pricing agreements (“APA”)

16/06/2021 Yusuf Wangko Ngantung, DDTC, Indonesia

German 2021 Transfer Pricing — A Fundamental Shift in the German Transfer Pricing Landscape

Sometimes the most radical shifts in life announce themselves in seemingly small details. The same can be said about the fundamental shift that is about to occur in German transfer pricing

16/06/2021 Philip de Homont, NERA Economic Consulting, Germany Yves Hervé, NERA Economic Consulting, Germany

No state aid to Amazon, rules the General Court of the EU

On 12 May 2021, the General Court of the European Union overturned the decision of the EU Commission (“Commission”) rendered on 4 October 2017 (S.A. 38944) according to which Luxembourg granted state aid to Amazon.

15/06/2021 Antonio A Weffer, Baker McKenzie, Luxembourg Elodie Schmidt, Baker McKenzie, Luxembourg

Luxembourg: Ahead of the curve on transfer pricing matters

Over the last decade, Luxembourg has taken great steps forward in aligning its transfer pricing (“TP”) regulations to the international standards

15/06/2021 Marc Rasch, PwC, Luxembourg Caroline Goemaere, PwC, Luxembourg Christophe Hillion, PwC, Luxembourg Ludovicus (Loek) De Preter, PwC, Luxembourg

Future proof now, not later, as transfer pricing scrutiny evolves

Look at any of the largest tax audit and litigation cases of the last few years and it is more likely than not that some form of transfer pricing (TP) sits at – or very near — the heart of each one

10/06/2021 Luis Coronado, EY, Singapore

Inglorious end of a journey: how the German Constitutional Court stopped the tax administration and the Federal Tax Court, and what taxpayers can learn from it

Starting with its judgement I R 73/16 from 2019, the First Senate of the Federal Tax Court had embarked on a journey during which it has served an unparalleled series of decisions against German taxpayers and, thereby, has thrown overboard a consistent and well-reasoned legal position on outbound...

01/06/2021 Ulf Andresen, DLA Piper, Germany

Intra-group financing garners more ‘interest’ now

The finance function has always been one of the center pillars for success of any business as financial transactions are the most critical and material transactions

18/05/2021 Maulik Doshi, Nexdigm (SKP), India

The Impact of OECD GloBE Proposals in the Middle East

Shiv Mahalingham, of Cragus, sets out a summary of the key proposals for Global Anti-Base Erosion under Pillar Two and looks at the potential impact on the Middle East, North Africa (MENA) region (a region that is at present characterized by the introduction of new/revised transfer pricing...

13/05/2021 Shiv Mahalingham, The Cragus Group, United Arab Emirates

Is the OECD Inclusive Framework Digital Project the Beginning of the End of the Arm’s Length Standard?

This is not the end. It is not even the beginning of the end. But it is, perhaps, the end of the beginning.”

13/04/2021 Michael F Patton, DLA Piper, US

Insight: The OECD Guidance on Covid-19: How it May Apply to Your 2020 Financial Adjustments

The unique economic conditions arising from COVID-19 have seriously impacted financial performance raising the question of how these impacts should be shared.

07/01/2021 Glenn DeSouza, Dentons, China

International – the importance of regular evaluation of transfer pricing policies

Over the last couple of years, the number of specific transfer pricing audits has risen sharply across the globe

20/04/2020 Danny Oosterhoff, EY, Netherlands

What Transfer Pricing Practice could Reference from COVID-19 Impacts – Respond, Recover and Thrive

The transfer pricing ("TP") practice aims to mimic the intercompany arrangements and profits allocation by reference to independent parties in similar circumstances.

14/04/2020 Eunice Kuo, Deloitte, China Victor Zhang, Deloitte, China

The Impact of COVID-19 on Transfer Pricing

This article looks at the current COVID-19 crisis and the impact it will have on Transfer Pricing and Multinational Enterprises (MNEs) who are dealing with Transfer Pricing issues.

29/03/2020 Shiv Mahalingham, The Cragus Group, United Arab Emirates

Planning for Digital Intangibles in Economic Ups and Downs

Investments in intangibles have increased dramatically over the past few years

27/03/2020 Yves Hervé, NERA Economic Consulting, Germany Alexander Vögele, NERA Economic Consulting, Germany

Transfer Pricing Expert Guide 2019 is now live

Welcome to the Legal Media Group (LMG) Transfer Pricing Expert Guide, 11th edition

27/08/2019

The IRS’s new Transfer Pricing Examination Process manual: how it can be used by multinational taxpayers

The IRS on June 29 released a new manual for IRS personnel, the Transfer Pricing Examination Process, replacing the 2014 Transfer Pricing Audit Roadmap

07/08/2019 Marc M Levey, Baker McKenzie, US

Global trends in transfer pricing

Numerous, interrelated global trends in the transfer pricing landscape have emerged, including growth of the digital economy, challenges to the arm’s length standard, increasing tax authority and taxpayer use of big data and discussions on the compensable value of data, and the increasingly favored...

07/08/2019 Guy Sanschagrin, WTP Advisors, US Doug Schwerdt, WTP Advisors, US

Can the Arm’s Length Standard be Used to Resolve Tax Challenges of Digitalisation of the Economy?

For the past several years the question of how to tax the digital economy, both for companies specializing in digital activities (search engines, on-line market places, social media) and the on-line activities of companies more broadly has been a key concern for tax administrators

07/08/2019 Michael F Patton, DLA Piper, US Paul Flignor, DLA Piper, US

Q&A with John Wells

What was the most significant development in your region/jurisdiction's transfer pricing practice in the past 12 months?

07/08/2019 John M Wells, Deloitte, US

Use of comparable with losses and its rejection by the Tax Administration in Venezuela: a controversy case

As it is known, and as set out in the OECD guidelines, when applying the Transactional Net Margin method, specifically in the process of searching for functionally comparable companies that may include comparable companies with losses for more than two years, it should be taken into account that the...

07/08/2019 Nelson Landaeta Contreras, NLC Asesoría, Venezuela

Economic substance and arm’s length –Mexico

Mexican taxpayers are obliged to determine their taxable income and authorized deductions derived from related party transactions considering the prices that would have been used in comparable transactions with or between independent parties

07/08/2019 Oscar Campero, Chévez Ruíz Zamarripa y Cía, Mexico Yoshio Uehara, Chévez Ruíz Zamarripa y Cía, Mexico

The Patent Box and the recent development under the Italian Tax Rules

The Patent Box Decree introduced in Italy an elective tax regime that will allow companies to benefit (starting from fiscal year 2017) from a 50% exemption from corporate income tax, IRES, and local tax, IRAP, on income derived from the direct/indirect exploitation of qualifying IP

07/08/2019 Susanna Scapigliati, Morri Rossetti e Associati, Italy

Three Transfer Pricing Earthquakes – HTVI, DAC6, and ICAP

Tax authorities in many countries are heavily investing in their field tax audit teams and systems

07/08/2019 Philip de Homont, NERA Economic Consulting, Germany Alexander Vögele, NERA Economic Consulting, Germany

Growing beyond borders – Multinationals are responding with virtual teams and matrix organizations – How to keep up from a transfer pricing perspective

The global war of talents and a new era of a digitally connected global economy – just to name two challenges multinationals are increasingly facing

07/08/2019 Michael Freudenberg, KPMG, Germany Felix Bussmann, KPMG, Germany

Q&A with Willy De Molina

What was the most significant development in your region/jurisdiction's transfer pricing practice in the past 12 months?

07/08/2019 Juan Ignacio de Molina, Deloitte Legal, Spain

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