Topic
Transfer Pricing
302 published works
International Financial Law Prof Blog
Final OECD Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10
The report is significant because it is the first time the OECD Transfer Pricing Guidelines include guidance on the transfer pricing aspects of financial transactions, which will contribute to consistency in…
Global Media and Communications Watch
Tech Tax – Looking Forward to 2020
By Graham Poole, Philip Harle, Adam Parry
Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics…
Tax Controversy 360
Code Sec. 367(a) and (d) After the TCJA
Code Sec. 367(a) and (d) subject to taxation a transfer of tangible and intangible property by a U.S. person to a foreign corporation in an otherwise tax-free transaction. While for…
International Financial Law Prof Blog
U.S. Country-by-Country Report, Tax Year 2017
Six new tables presenting data from Form 8975, Country-by-Country Report, and Form 8975 Schedule A, Tax Jurisdiction and Constituent Entity Information, are now available on SOI's Tax Stats Web page. The tables…
International Financial Law Prof Blog
Brazil agrees to change its transfer pricing rules to OECD Guidelines
Brazil has identified a clear pathway for bringing its existing transfer pricing framework into alignment with the international consensus, and is weighing two options – immediate or gradual implementation, according…
International Financial Law Prof Blog
Starbucks and Netherlands APA Upheld by European Court of Justice
The General Court annuls the Commission’s decision on the aid measure implemented by the Netherlands in favor of Starbucks (released by the Court) For William Byrnes analysis of this State…
International Financial Law Prof Blog
Will Amazon and Altera Lead to an En Banc Redux?
A Ninth Circuit panel handed down the Amazon[1] decision on Friday (August 16) in favor of Amazon. On June 7, a different Ninth Circuit panel handed down Altera[2] in favor…
The Cyprus Lawyer
Tip 3.1 – Cyprus Tax – Related Party Transactions to be at arm’s length in Cyprus
By HSharpe
Article 33 of the Income Tax Law The Cyprus income tax law forbids related party transaction to carry out on preferential terms. Effectively disallowing any preferential treatment afforded due to…
Tax Controversy 360
Weekly IRS Roundup August 5 – 9, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5 – 9, 2019. August 5, 2019: The IRS…
Tax Controversy 360
IRS Resumes Examinations of Stock Based Compensation in Cost Sharing Agreements
By Andrew R. Roberson, Kevin Spencer, McDermott Will & Emery
On July 31, 2019, the Internal Revenue Service (IRS) Large Business and International (LB&I) division formally withdrew its Directive (LB&I-04-0118-005) instructing examiners on transfer pricing selection related to stock based…