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Transfer Pricing

302 published works

  1. International Financial Law Prof Blog

    Nike State Aid case analysis: Would you pay $100 for a canvas sneaker designed the 20’s?

    By William Byrnes

    Where does the residual value for "Just Do it" and the 'cool kids' retro branding of All Stars belong? I have received several requests in the U.S. about my initial…

  2. Israel Global Gateway

    Transfer Pricing Challenges of the Digital Economy

    By Israel Group

    Lewis J. Greenwald (Partner) and Naftali Z. Dembitzer (Of Counsel) from DLA Piper‘s New York office, presented at a tax conference that was held on June 12, 2019 at the…

  3. Israel Global Gateway

    Event: Transfer Pricing Challenges of the Digital Economy

    By Israel Group

    Please join us on June 12 for a Transfer Pricing event featuring our colleagues Lewis Greenwald and Naftali Dembitzer, from our New York office. Click here to register.

  4. Tax Controversy 360

    IRS Announces More LB&I Campaigns!

    By Andrew R. Roberson, Kevin Spencer, K. Christy Vouri-Misso

    The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage, please click here. The most recent set of…

  5. International Financial Law Prof Blog

    OECD Offers Revenue Officials International Tax E-Learning

    By William Byrnes

    The OECD’s Global Relation Programme offers tax officials from developing countries the necessary training to tackle today’s most pressing challenges in international taxation. These events are offered free of charge…

  6. DLA Piper Latin America – Law Blog

    Brazil: recent changes in transfer pricing rules

    By DLA Piper

    On January 30, 2019, Normative Instruction n° 1,870/2019, issued by the Federal Revenue Office (RFB), was published in Brazil’s Official Gazette, amending several provisions of Normative Instruction n° 1,312/2012, which…

  7. The CPA Desk

    A Closer Look at Transfer Pricing and the International Space

    By PKF Texas

    https://youtu.be/um8zMSjOozo Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to The…

  8. International Financial Law Prof Blog

    “International Tax Cooperation” Congress 2019: Digital  Economy, Transfer Pricing and Tax Administration. Ongoing 2030 (SDG) and Addis Ababa Agendas

    By William Byrnes

    PROPOSAL TO SIMPLIFY THE REGULATION OF BEPS- OECD- FOR TRANSFER PRICESSol Piccioto, Emeritus Professor, Lancaster University. United Kingdom CRITICAL ASSESSMENT OF BEPS' V. US' SOLUTION OF BEAT AND GILTI, POLICY…

  9. International Financial Law Prof Blog

    EU State aid investigation opened into Nike’s tax treatment in the Netherlands

    By William Byrnes

    Loyens & Loeff reports: On 10 January 2019, the European Commission announced the opening of a formal State aid investigation into five tax rulings granted by the Dutch tax authorities…

  10. Global Media and Communications Watch

    UK Tax Authority tightens the screws on tech companies

    By Graham Poole, Rupert Shiers, Tom McFarlane

    When is an amnesty not an amnesty? When the carrot is the (possible) absence of stick. HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This…