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Workshop For Corporates - "Fit For Future: A Refined Approach To Tax Risk Management"
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February 22nd, 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.
CFO's Journey from 'Staying Out Of Trouble' to being 'Fully In Control'
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February 22nd, 2019
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):
Introduction.
South Africa Mulls To Broaden The Reach Of Its Transfer Pricing Rules
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February 21st, 2019
South Africa released its 2019 budget review in February 20, which outlines several international tax proposals for implementation or evaluation, including a possible change to the Income Tax Act’s transfer pricing rules and adoption of OECD’s model mandatory disclosure.
Broadening the Definition of ‘Affected Transaction’ .
Ireland Amends The Transfer Pricing Rules To Better Harmonize With OECD Standards
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February 21st, 2019
The Irish government has called for input on proposals designed to better harmonize domestic transfer pricing rules with OECD standards, including adoption of the authorized OECD approach (AOA) to profit attribution and enhanced documentation rules.
Incorporation of the BEPS Action 8-10 and Action 13 .
French Court Fines UBS EUR 4.5 Billion For Aiding Tax Evasion
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February 21st, 2019
A Paris criminal court has held that UBS Group AG engaged in aggravated money laundering and tax fraud when it illegally worked to establish hidden Swiss bank accounts for its French customers to aid them avoid tax in France.
Background .
EU Commission: Scheme of Belgium Excess Profit Does Not Constitute State Aid
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February 20th, 2019
The General Court of the European Union issued a judgment that annuls a January 2016 State aid decision of the European Commission concerning Belgium's excess profit rulings.
Background .
Many Countries Keen To Modify Their Tax Treaty Network Against Treaty Abuse
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February 20th, 2019
The Organisation for Economic Co-operation and Development (OECD) released the first peer review report relating to the compliance by members of the Inclusive Framework (IF) on Base Erosion and Profit Shifting to the minimum standard on BEPS Action 6 for prevention of treaty abuse. The report covers 116 jurisdictions and information available as of 30 June 2018.
The Dutch House of Representatives Approves Multilateral Instrument (MLI)
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February 14th, 2019
The House of Representatives of the Netherlands of the Dutch Parliament approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). The ratification bill is yet to be approved by the Upper House (Eerste Kamer).
U.S. Territories Included in EU Money Laundering Blacklist
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February 14th, 2019
The European Commission issued the black list for money laundering on 13 February 2018. The list also consists of four U.S. territories including Guam, American Samoa, U.
Belgium Publishes Circular Letter On Transfer Pricing Reporting Penalties
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February 14th, 2019
The Belgian Federal Public Service (SPF) Finance published Circular Letter No. 2019/C/14, which clarifies the application of penalties for failing to fulfill transfer pricing reporting obligations.
Sale Of Stock Subject To French Transfer Pricing Rules
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February 12th, 2019
The French Council of State has upheld a transfer pricing adjustment to the sales price of a subsidiary’s shares, holding that the sale of a subsidiary’s stock for nominal consideration is an indirect transfer of profit.
Facts .
Peru Clarifies The Attribution Of Net Passive Income Of Controlled Foreign Corporations (CFC)
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February 12th, 2019
The Tax Administration ( Superintendencia Nacional de Administración Tributaria , SUNAT) published on its website Report 097-2018-SUNAT/7T0000 (the Report), clarifying the attribution of net passive income of CFC rules for its Peruvian shareholders.
CFC Rulings .
Tunisia Clarifies The Determination And Disclosure Of Ultimate Beneficiaries
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February 7th, 2019
In an effort to prevent money laundering and fight the financing of terrorist activities, Tunisia has recently adopted requirements for the identification and registration of the ultimate beneficial owners of corporations and other entities registered in Tunisia.
Ultimate Beneficiaries .
U.S. Treasury Department Publishes List Of Boycott Countries That Result In Restriction Of Tax Benefits
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February 7th, 2019
The U.S. treasury department has issued the list of the countries that require cooperation with, or participation in, an international boycott as a condition of doing business.
Countries Lists .
EU Code Of Conduct Group Not Satisfied With Changes On Certain Harmful Regimes
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February 7th, 2019
The EU Code of Conduct Group (Business Taxation) has sent letters to six jurisdictions in relation to the EU list of non-cooperative jurisdictions for tax purposes as their new preferential tax regimes will not be sufficient to keep their country off the 2017 EU blacklist. The letters emphasizing the EU dissatisfaction were sent to Barbados, Belize, Curaçao, Mauritius, Saint Lucia, and Seychelles.
Sweden Plans To Transpose The 2017 EU Hybrid Mismatches Rule Without Harming The Cross Border Investment
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February 5th, 2019
The Swedish government released a proposal to transpose the 2017 EU directive on hybrid mismatches without harming the cross border investment due to the excessive administrative burden.
The Details of the Proposal .
Danish Supreme Court Rules On Software Giant's Transfer Pricing Case
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February 5th, 2019
Denmark’s supreme court has affirmed a 2018 court decision in Microsoft’s favor regarding the company’s transfer pricing arrangements, holding that a Danish subsidiary maintained adequate documentation and used an appropriate revenue base for calculating its commission.
Facts .
TPA Global Forms Alliance With Arena Tax Sp. z o.o. (Poland)
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January 31st, 2019
Arena Tax is a licensed tax advisory company providing comprehensive solutions in tax advisory and transfer pricing within two teams: tax team and transfer pricing and valuation team. Currently is one of the 20 largest tax advisory companies in Poland, according to the daily newspaper Rzeczpospolita .
Russia Clarifies The Conditions For Claiming Permanent Residence And Beneficial Ownership For Tax Treaty Purposes
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January 31st, 2019
Russia through its Guidance Letter 03-08-05/92537 and Order Number MMB-7-2/824 clarifies the conditions for claiming permanent residence and beneficial ownership for tax treaty purposes.
Details .
OECD - Progress On Addressing The Tax Challenges Arising From Digitalization Of The Economy And Harmful Tax Practices
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January 31st, 2019
The OECD has issued a release announcing that the international community has made important progress towards addressing the tax challenges arising from the digitalization of the economy and has agreed to continue working multilaterally towards achievement of a new consensus-based long-term solution in 2020. In addition, the OECD has also issued a release on progress made in addressing harmful tax practices.
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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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