Transfer Pricing

UK country-by-country reporting notification deadline approaches

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Source: Deloitte Global Transfer Pricing Alert 2017-033

“The first country-by-country (CbC) reporting notifications required to be made to the UK tax authorities are due by 1 September 2017.

This deadline applies to all reporting periods that end on or before 1 September 2017.

After 1 September 2017, the standard UK notification date is the end of the CbC reporting period.

A few examples regarding the application of these rules follow.
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OECD claims major progress reported towards a fairer and more effective international tax system

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Source: OECD Press release 5 Just 2017

The latest Report from OECD Secretary-General Angel Gurría to G20 Leaders  describes the continuing fight against tax avoidance and tax evasion as one of the major success stories of the G20, founded on enhanced international co-operation.

The report, released 5th July 2017, updates progress in key areas of OECD-G20 tax work, including movement towards automatic exchange of information between tax authorities and implementation of key measures to address tax avoidance by multinationals.

“Tax issues have been a key priority of the G20 since its inception, and 2017 is the year of implementation,” Mr Gurría said. “In the midst of the backlash against globalisation, we need to deliver on an agenda of inclusive growth. The work of the G20 and the OECD to repair and improve the international tax system so everyone pays their fair share remains one of the most important responses to these challenges, as well as one which is having a concrete impact.”

Source press release here

 

Public Discussion Draft – BEPS ACTION 10 – Revised Guidance on Profit Splits

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DRAFT REVISED GUIDANCE ON THE TRANSACTIONAL PROFIT SPLIT METHOD (TO REPLACE PART III SECTION C OF CHAPTER II OF THE 2010 TRANSFER PRICING GUIDELINES)

Source: OECD Discussion Draft, 22 June 2017. Deadline for responses – 15 September 2017

Public comments are invited on this discussion draft which deals with the clarification and strengthening of the guidance on the transactional profit split method, as set out in the BEPS Actions 8-10, 2015 Final Report.

This draft sets out the text of proposed revised guidance on the application of the transactional profit split method, together with a number of questions, listed below. Read the rest of this entry »

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 »