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Workshop For Corporates - "Fit For Future: A Refined Approach To Tax Risk Management"
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May 9th, 2019
During the past few years, the EU commission and many local governments have released a number of aggressive and uncoordinated initiatives to curb unwanted tax behaviour of multinationals, following the 2015 release of the BEPS Action Plans by the OECD/G20.
Consequently, MNEs are experiencing an increased exposure to tax controversies if they are not simultaneously in control of their Operating and Tax/Transfer Pricing models.
Do You Want to Become a Big Tax Data Specialist?
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April 19th, 2019
FACT : many processes will be automated and therefore the role of the tax advisor will be changing.
To implement a tax technology solution, a whole host of other skills is required.
TPA Global Is Expanding Its Global Partner Network To Deliver 'State Of The Art' Tax And Transfer Pricing Solutions
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April 19th, 2019
Given the recent push for more transparency by tax authorities, the BEPS project has also triggered a whole host of governance aspects on tax matters. In order to fully support our multinationals’ clients to be 'fully in control on their global tax positions', TPA Global has been building 3 pillars of solutions, which include:
Value Chain Analytics - through a new generation of benchmarking, a quantitative VCA is being performed in BEPS and court compliant manner.
Google’s Ireland Tax Deal Draws EU Concerns
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April 19th, 2019
Google’s Irish operations are coming under closer scrutiny from Europe over corporate tax affairs. The European Union has taken a closer look at how Google uses operations in Ireland to help reduce its corporate tax obligations within the trade bloc.
German Ministry Of Finance Issues Draft Bill On Tax Dispute Resolution Mechanisms In EU
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April 19th, 2019
Germany's Ministry of Finance has published the draft law for the transposition of Council Directive (EU) 2017/1852.
Background
Chinese Ministry Of Finance Introduces Tax Breaks For Innovative Companies Depository Receipts
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April 19th, 2019
China's Ministry of Finance announced the launch of a pilot program providing new tax incentives to support China innovative-driven strategy, which includes incentives for investments in Chinese Depository Receipts (CDRs) issued by innovative Chinese enterprises. CDRs are similar to American Depositary Receipts (ADRs), which are negotiable securities that represent shares of a foreign company.
Latin America To Offer Solution To Tax Digital Economy
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April 16th, 2019
At an event hosted by the Inter-American Dialogue, Ubaldo González (Senior Sector Specialist in Tax Administration, Inter-American Development Bank) explained that Latin American countries face unique challenges, including revenue shortages that threaten their ability to meet the U.N.’s 2030 Agenda for Sustainable Development.
Dutch Government To Start A Series Of Investigations To Improve The Tax System
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April 16th, 2019
The Dutch government will start a series of new investigations to improve the tax system. The investigation will reassess the tax system that will examine the current tax mix and its distributive effects, taxation of income from digital sources, and the future of corporate taxation.
TPA Global Forms Alliance With CARA Advocats (France)
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April 15th, 2019
CARA Avocats is a genuine law firm created by former Big-4 professionals with extensive experience in transfer pricing and international corporate tax. The firm rapidly became a leading transfer pricing advisory services provider for French large MNEs and mid-sized companies in the French South-East region.
EU Joint Transfer Pricing Forum Publishes Report On The Application Of Profit-Split Method Within EU To Complement The OECD Guideline (2)
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April 12th, 2019
The EU joint transfer pricing forum (JTPF), has released a report on the application of the profit-split method. The report is intended as the first part of a two-stage process, beginning with the clarification of certain concepts, while the second stage will explore simplification.
UN Tax Committee To Update The United Nations Practical Manual On Transfer Pricing For Developing Countries
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April 11th, 2019
The UN Committee of Experts on International Cooperation in Tax Matters published a draft document to update the United Nations' Practical Manual on Transfer Pricing for Developing Countries. The draft includes a new chapter on financial transactions, revised text on profit splits, and revised text on establishing transfer pricing capability, risk assessment and transfer pricing audits.
Turkey To Gradually Lower Corporate Tax Rate Under Its New Set Of Tax Reforms
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April 11th, 2019
Turkey’s Treasury and Finance Minister Berat Albayrak announced a new economic reform package. It includes significant changes in the tax regime, financial structure, agricultural policies and capital markets.
Dutch Parliament Vigorously Insists Shell Attends Tax Avoidance Hearing
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April 11th, 2019
The Dutch parliament will insist on Shell sending a representative to attend a hearing on tax avoidance by multinationals. The warning is given as Shell’s Dutch Chief Executive had previously declined the invitation.
Malaysian Parliament Approves Bill To Impose Service Tax On Digital Services
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April 10th, 2019
The Malaysian government approved the Service Tax (Amendment) Bill 2019, which provides for the taxation of digital services. The service tax applies to foreign service provider making supplies to Malaysian consumers (B2C) which starts from 1 January 2020.
European Tax Advisers Support EU Court’s Transfer Pricing Ruling
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April 10th, 2019
The European Union’s top court provided “an important clarification” on the conditional compatibility of domestic and bloc wide law when it ruled that Germany must allow multinational companies to justify their transfer pricing arrangements.
The Ruling .
UN Tax Committee Proposes To Update The Model Tax Treaty
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April 5th, 2019
The UN Committee of Experts on International Cooperation in Tax Matters published several documents in tax matters. Two of the documents are discussing possible updates to the UN Model Double Taxation Convention between Developed and Developing Countries commentary on permanent establishments and beneficial ownership.
Japan’s Parliament Passes 2019 Tax Reform Bill
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April 5th, 2019
Japan's National Diet (parliament) reportedly approved the legislation for the government's tax reform proposals for 2019. The amendments with regard to corporate taxation encompass transfer pricing, earning stripping rule, and Controlled Foreign Corporation (CFC) rules.
European Commission Finds UK CFC Law Partially Granted State Aid
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April 5th, 2019
On 2 April 2019, the European Commission announced its decision that the group financing exemption allowed under the UK's controlled foreign company (CFC) Rules gave an illegal tax advantage to certain multinationals, constituting illegal State aid.
UK CFC Rules .
2019 TP Country Summaries Update (1)
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April 2nd, 2019
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical Transfer Pricing Country Summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
This week we updated the following online TP Country Summaries:.
OECD Proposals Undermine The Arm’s Length Principle
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March 29th, 2019
The Organisation for Economic Cooperation and Development (OECD) recently released a policy note (approved by the 127 members of its Inclusive Framework (IF)), hosted a webcast and held a public consultation meeting to consider possible solutions to the tax challenges arising from digitalization of the economy.
The policy note recognizes that the digitalization of the economy is pervasive, raises broader issues, and is most evident in, but not limited to, highly digitalized businesses.
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With the fast growth of China’s economy and the continuous improvement of the comprehensive strength of domestic enterprises, as well as the implementation of the “One Belt, One Road” policy, an increasing amount of Chinese enterprises are beginning to expand their global footprint and establish their presence in Europe.

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CFO's Journey from 'Staying Out Of Trouble' to being 'Fully In Control'

TPA Global has developed a practical roadmap of 6 steps meant to guide CFOs in their Journey of rising above troubles to reach a situation of full control. These steps are presented in a series of short video clips (3-5 minutes):

Roadmap for CFO's

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