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Archive for Transfer Pricing
The issue of transfer pricing has never been a bigger issue than now. With news of the IRS auditing U.S. corporations who operate outside of the country, the Organization for Economic Cooperation and Development (OECD) latest action plans under the Base Erosion Profit Sharing (BEPS) project, and the U.K. voting to leave the European Union (Brexit), the effects with be seen by U.S. multinationals. You have the opportunity to learn from top tax experts who will discuss and analyze the transfer pricing market.
Transfer Pricing Summit—Nationally Recognized Transfer Pricing Experts Teach You What You Need To Know Today!
Now that the United Kingdom has voted to leave the European Union, the question of how this will affect the global economy is one of the crucial issues for U.S. multinationals. The effects will have far reaching implications in transfer pricing and cross border activities. U.S. Multinationals are already considering the impact on and possible outcomes the vote will have on their businesses. In addition, to the direct trade effect, business investment around the globe is likely to be stifled somewhat due to the heightened uncertainty about the global implications of BREXIT and the tightening of financial conditions. Don’t miss this opportunity to learn from our tax experts, who will discuss and analyze the effects on transfer pricing and the global outlook on this decision, as well as, the OECD’s latest action plans under the BEPS (base erosion profit shifting) project and modifications to bilateral tax treaties.
Transfer pricing is a complex issue currently affecting multinational enterprises (MNEs) and tax authorities of both developed and developing nations. The OECD, EU, UN, IRS and others are all preparing adjustments of tax schemes to improve clarity, ease dispute resolution, and provide for analysis and penalties for transfer mispricing. In increasing the number of both transfer pricing audits and adjustments in recent years, Read more
Transfer pricing methodologies are beginning to spread far beyond the narrow confines of section 482. Consider two very recent examples:
• Argentina had enacted revenue raising measures designed to penalize companies that would shift profits from Argentina to a tax haven. Argentina used an OECD BEPS transfer pricing rationale in enacting these anti-tax-haven provisions. Most Argentinian enterprises that make use of tax havens use Panama for that tax haven purpose, in part because of the commonality of language. Panama sued Argentina, arguing that the Argentinian tax restrictions are an artificial trade constraint. Panama brought suit at the World Trade Organization (WTO). Other countries are now involved. Panama won the initial round at the WTO, but Panama has joined the OECD’s Global Forum, a measure that would ultimately bring the country into compliance with the OECD’s Transfer Pricing Guidelines. Panama’s attack is similar to the attack on DISC before GATT three decades ago
TaxConnections would like to introduce Dr. Daniel Erasmus, Managing Partner and Transfer Pricing Expert at Tax Risk Management.
An Enrolled Agent and a member of the US Tax Court Bar in all 50 states, his experience as international attorney has led him and his team to represent clients all over the world in tax controversies, especially transfer pricing in Africa.
These clients include:
Various US clients;
A major German car manufacturing company;
The 2nd largest beer brewer in the world; Read more
Vanguard faces a whistle-blower lawsuit filed by its former in-house tax attorney, who claims that the company’s unique structure and intercompany management fees violate tax code Section 482, as well as New York Tax Law Section 211(5). A report submitted to federal authorities in support of a whistleblower claims Vanguard Group Inc. owes $34.6 billion in taxes because it undercharges its affiliated mutual funds for investment advisory services, resulting in a reduced federal tax liability.
Under federal tax rules, services must be priced at arm’s length, or as if between unrelated companies, unless they are subject to an exception, which Vanguard is not.
“Vanguard has no legal justification for its transfer pricing practice of operating its U.S. Read more
We hear a lot about the OECD’s BEPS project (base erosion and profit shifting) and its action items. What is the relevance of “country-by-country” reporting for transfer pricing documentation? Does the statement on harmful tax practices mean that the US should adopt a patent box? The 31st Annual TEI-SJSU High Tech Tax Institute, scheduled for November 9 and 10, 2015 in Palo Alto, will address these questions and more. A BEPS panel will include attorneys from China, Ireland and the U.S. to share how other countries are responding the BEPS project and what it means for your company or clients. Another panel with practitioners from the UK and Ireland will explore hot topics in the EU. Heather Maloy, (former) Commissioner for the IRS Large Business & International Division will also be speaking, along with numerous other experts on hot tax topics for high tech Read more
International Tax Review / TPWeek interviewed 180 leading in-house tax professionals to discover their opinions on the Base Erosion and Profit Shifting (BEPS) project and what shape their transfer pricing strategies are taking as final BEPS guidance draws near. As the Infographic shows below, the approach of these tax executives proved to be very interesting.
Where do you and your tax organization stand on being prepared for BEPS? Are you being proactive in your approach for responding to BEPS? Are you doing nothing at all until the project is finalized?
See Infographic below: Read more
Corporate Heads of Tax and Transfer Pricing will meet to discuss how best to approach the issue of integrating technology systems in light of pending BEPS guidance.
The leaders will meet in Washington DC on September 24 and 25 at the Park Hyatt hotel as part of TPWeek and International tax Review’s Global transfer Pricing Forum.
The forum opens with a panel discussion on technology responses to BEPS and will look at operational TP, data analytics and country-by-country reporting.
As the BEPS process continues to evolve, one thing that is clear is that taxpayers will face a need for more information and greater reporting to various tax authorities. Read more
The South African Revenue Service (SARS) has announced an amnesty of sort – a threat and upfront warnings: we do know about you, best you come forward before we make the tax audit into your affairs known.
On July 9th, 2015, SARS issued a press release, which can be read in more detail on:
The International Consortium of Investigative Journalists (ICIJ), based information obtained by French newspaper Le Monde, ranked South Africa number 31 among the countries with the largest amount of dollars ($2.3blion) in the so-called leaked Swiss Read more