Transfer Pricing

Recent Indian TP court ruling suggests change of direction on AMP expenses

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The case of Luxottica India Eyewear Pvt. vs Acit was heard in New Delhi on 23 May 2017 and the decision on 25 May has created new uncertainty for multinationals operating in India. Read the rest of this entry »

The Approach to Hard-to-Value Intangibles: OECD Discussion Draft released.

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On May 23 2017 the OECD released a public discussion draft on the implementation guidance on Hard-to-Value Intangibles (HTVI).

This discussion draft presents the principles that should underlie the implementation of the HTVI approach, provides examples illustrating the application of this approach and addresses the interaction between the approach to HTVI and the mutual agreement procedure. Read the rest of this entry »

“Google settles huge £259m tax bill to end criminal investigation into alleged avoidance”

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Source: 4th May 2017

“Google will pay €306m (£259m) to settle a tax dispute in Italy and end a criminal investigation into whether it avoided paying the full amount on its revenues in the country for more than a decade.

The agreement resolves a series of disputes including a criminal probe that saw police accuse Google of booking around €1bn of revenues from Italy in Ireland between 2009 and 2013.

The payment that Italy has secured is significantly higher than the £130m that Google agreed to pay the Treasury last year for a decade of underpaid taxes, and is the latest crackdown from Europe. George Osborne, the chancellor at the time, was criticised for letting Google off easy.”

Source article here


“Diageo told to pay £107m in extra tax” in UK profits row

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Source: 10th May 2017

“Diageo has been ordered to pay £107m by the UK tax authority as part of a long-running investigation into moving profit between its global businesses.

The drinks giant said that under the new Diverted Profits Tax regime, HMRC will ask for more tax and interest for the past two financial years.

Diageo said it would challenge the HMRC’s assessment.

However, the company said it will have to pay £107m then work with HMRC to resolve the issue.”

Source article here