Expert Guides - Transfer Pricing

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, Chevez Ruiz Zamarripa, 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 LLP, the Deloitte UK member firm, United Kingdom 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

Norway – Recent corporate tax and transfer pricing developments

As in other OECD-countries, protecting the domestic tax base whilst at the same time reducing the statutory corporate tax rate in order to stay internationally competitive, is a main concern for Norwegian lawmakers

18/07/2017 Terje Arntzen, Arntzenlegal, Norway

Interest Expense Deductions: A new challenge

On 5 October 2015, the OECD released its final report on recommended limitations on interest expense deductions (“Action 4”) under its Action Plan on Base Erosion and Profit Shifting (BEPS)

18/07/2017 Antonio A Weffer, Baker & McKenzie., Luxembourg

BEPS Action 13 impact on a non-OECD/G20 jurisdiction

This article intends to give a perspective of the challenges that MNEs may confront when dealing with non-standard documentation, based on the first year experience of the Action 13 implementation in one of the non-OECD/G20 countries.

17/07/2017 Alexis Carrera, EY, Ecuador Fernanda Checa, EY, Ecuador

Mexico publishes final master file, local file, and CbC report rules

Mexico’s Tax Administration Service (SAT) on 12 April published on its website the final compliance rules regulating the contents and filing of the master file, local file, and country-by-country (CbC) report, as well as a report on the public consultation conducted by the Taxpayer’s Ombudsman...

17/07/2017 Simón Somohano, Deloitte, Mexico Arturo Vela, Deloitte, Mexico Kaidi Liu, Deloitte, US

Dangerous Shallows - The Hazard of Simplistic Transfer Pricing Master Files

The OECD has mandated the “Masterfile” concept for the transfer pricing documentation of taxpayers

13/07/2017 Alexander Vögele, NERA Economic Consulting, Germany Philip de Homont, NERA Economic Consulting, Germany

German transfer pricing developments in light of BEPS implementation

In light of BEPS implementation, the current German transfer pricing landscape is characterized by a dynamically changing environment

13/07/2017 Axel Eigelshoven, PwC, Germany Gerrit Halbach, PwC, Germany

France: Tax authorities have more and more tools to audit transfer pricing

For several years, tax audits of French companies belonging to multinational groups include quasi systematically an audit of their transfer pricing policies

07/07/2017 Xavier Daluzeau, CMS Bureau Francis Lefebvre, France

Formal transfer pricing documentation filing requirements in Belgium

In line with the guidance provided by the OECD in Action Point 13 of its Base Erosion and Profit Shifting (BEPS) reports, Belgium introduced transfer pricing documentation requirements by means of the Law of July 1, 2016 (Belgian Official Gazette of July 4, 2016) and the related Royal Decrees dated...

07/07/2017 Dirk Van Stappen, KPMG, Belgium

India – Revised Country Chapter to United Nations Transfer Pricing Manual

As part of the recently released report on the work done by the sub-committee on transfer pricing (TP) of the United Nations (UN), it is noted that India has revised its country chapter on TP

07/07/2017 Rahul K Mitra, KPMG, India

Australia’s new transfer pricing world: Are you ready?

Over the past 18–24 months, there have been significant developments in the transfer pricing arena, both globally and in Australia

07/07/2017 Ockie Olivier, Deloitte, Australia Janelle Sadri, Deloitte, Australia Nicole Chiam, Deloitte, Australia

Reflections on the Chevron debt financing transfer pricing case – a post-BEPS decision?

On 21 April 2017, Australia’s Full Federal Court rejected an appeal by the taxpayer in a case involving a credit facility extended to Chevron Australia Holdings Pty Ltd (CAHPL) by a US resident subsidiary of CAHPL

07/07/2017 Ockie Olivier, Deloitte, Australia Geoffrey Gill, Deloitte, Australia John Bland, Deloitte, Australia Christopher Thomas, Deloitte, Australia

Recent UK Transfer Pricing Developments – A Continued Focus on Base Erosion and Profit Shifting

Transfer pricing rules have been part of UK tax legislation since 1997, and most multinationals operating in the UK are required to self-assess compliance with the arm's length principle when completing their tax returns. The UK tax authorities have long seen transfer pricing as a key issue. In...

09/10/2015 Shaun Austin, Deloitte LLP, the Deloitte UK member firm, United Kingdom Aengus Barry, Deloitte, United Kingdom Alison Lobb, Deloitte, United Kingdom

Reflections on the OECD’s BEPS Transfer Pricing Initiatives to Date

The OECD's Base Erosion and Profit Shifting ("BEPS") initiatives have already altered the international tax landscape dramatically, although the dust is far from settled. Tax planning structures that multinational firms have widely employed may no longer be viable. Firm-specific tax rulings do not...

30/09/2015 Elizabeth King, Beecher Consulting, US

Financial Reporting and Transfer Pricing Valuations: One Size Does not fit All

2015 is shaping up to become one of the largest years on record for M&A activity.¹ For many companies involved in such transactions, an inevitable outcome will be the preparation of purchase price allocation analyses (PPAs) in order to satisfy financial reporting requirements. At the same time,...

30/09/2015 Michael Heimert, Duff & Phelps, US

The U.S. Tax Court’s Altera Decision and its Implications

In Altera Corp. v. Commissioner, the U.S. Tax Court (USTC) held that a Treasury regulation requiring participants in a qualified cost sharing arrangement (QCSA) to share stock-based compensation costs (SBC) is invalid.

The Altera decision was the outcome of cross-motions for partial summary judgment...

30/09/2015 Philippe G Penelle, Deloitte Tax, US

The State of Transfer Pricing Audit Examinations in Canada – An Evolution in Sophistication

Canada's federal tax authority, the Canada Revenue Agency (CRA) is a mature and sophisticated tax authority by any measurable global standard. With approximately 40,000 employees, the CRA is responsible for the administration of tax laws in Canada for most of Canada's 10 provinces and three...

30/09/2015 Markus Navikenas MA, MBA, Deloitte, Canada Keith Falkenberg, Deloitte, Canada

Mexico implements country-by-country report and provides exemption from thin capitalization rules

Mexico's president on 8 September sent to Congress an economic package that includes proposed amendments to the Income Tax Law (ITL) and the Federal Fiscal Code (FFC) with transfer pricing implications. According to the legislation's explanatory memorandum, the goal is to incorporate the BEPS agenda...

30/09/2015 Simón Somohano, Deloitte, Mexico Jorge Mesta Espinosa, Deloitte, Mexico

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