Expert Guides - Transfer Pricing

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 PhD, 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, Bird & Bird, 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 Alexander Vögele, NERA Economic Consulting, Germany Philip de Homont, 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

Q&A with Shaun Austin

What was the most significant development in (the EMEA region’s TP practice in the last 12 months) your region/jurisdiction's transfer pricing practice in the past 12 months?

07/08/2019 Shaun Austin, Deloitte LLP, the Deloitte UK member firm, United Kingdom

Q&A with Clive Tietjen

What have been the most significant developments in transfer pricing compliance in the past 12 months?

07/08/2019 Clive Tietjen, Deloitte LLP, the Deloitte UK member firm, United Kingdom

Q&A with André Schaffers

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

07/08/2019 André Schaffers, Deloitte, Belgium

How the Singapore transfer pricing landscape has evolved over a decade

The recent “10 year challenge” that went viral on social media saw people comparing photos of themselves in 2009 to those taken in 2019

06/08/2019 Luis Coronado, EY, Singapore Jow Lee Ying, EY, Singapore

Draft profit attribution rules by India – Emergence of new controversy or end of it?

The concept of Permanent Establishment has as much history as the history of double tax conventions itself.

06/08/2019 Parikshit Datta, EY, India Nikhil Choudhary, EY, India

Q&A with Fiona Craig

What was the significant trend you have noticed in transfer pricing practices over the past 12 months?

04/08/2019 Fiona D Craig, Deloitte, Australia

Taxes & value creation in the digital economy

Digital transformation is rapidly accelerating. It continues to reshape all facets of our lives from how we do banking, order coffee, or book travel

25/04/2018 Emma Purdy, PwC, Canada

Transfer pricing adjustments – the current Irish landscape

The work of the OECD, the EU State aid investigations, public perception and the hunt for public funds by various Governments, mean that transfer pricing disputes will likely increase over the coming years

31/08/2017 Catherine O’Meara, Matheson, Ireland

OECD Master File Considerations: Overview of the OECD Master File

In October 2015, the Organisation for Economic Co-operation and Development (OECD) released its final report on Action 13 of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan)—Transfer Pricing Documentation and Country-by-Country Reporting

20/07/2017 Prita Subramanian, KPMG, US Tara Adams, KPMG, US

Clear, well-defined intercompany contracts are necessary in light of new BEPS rules

Under new base erosion and profit shifting (BEPS) guidance from the Organization of Economic Cooperation and Development, the concept of “delineation of the transaction” involves understanding the parties’ actual activities through a detailed functional and risk analysis

20/07/2017 Alan Shapiro, Deloitte, Japan Joe Tobin, Deloitte, US

Current environment of transfer pricing controversy in Mexico

Transfer pricing has become a major tax topic in Mexico’s tax audits. Multinational companies (MNEs) are starting to view this issue not only as a mere compliance requirement but as a strategic risk assessment area within the Company’s tax division

19/07/2017 Yoshio Uehara, Chévez Ruíz Zamarripa y Cía, Mexico Tania Ruiz, Chevez Ruiz Zamarripa, Mexico

Intra-Group Services And Their Effects In Colombia

In Colombia transfer pricing rules date back to the year 2002 when by means of the Law 788 of that year, articles from 260 to 260-11 were added to the Tax Code (TC)

19/07/2017 José Guarín, EY, Colombia

What are Intellectual Property Rights?

This article considers the precise nature of intellectual property rights so that due consideration can then be given to associated tax implications

19/07/2017 John Henshall, Deloitte, Denmark Roy Donegan, Deloitte, United Kingdom

Transfer pricing: the new order

This is a time of change in the world of transfer pricing

19/07/2017 Richard Fletcher, Baker McKenzie, United Kingdom

Transfer pricing environment in Spain: ready for the post-beps era

The preparation of a transfer pricing documentation and its content is well-known by Spanish corporate income taxpayers, who are obliged since 2009 to make available to the tax authorities a documentation describing their related-party transactions and justifying the arm’s length nature of the...

18/07/2017 Amaya Arrizubieta, Garrigues, Spain Mario Ortega Calle, Garrigues, Spain

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