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Searching Content indexed under Transfer Pricing by Jones Day ordered by Published Date Descending.
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1
Recent Developments In Transfer Pricing And The Taxation Of Multinational Companies In Australia
As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country's transfer pricing regulations.
Australia
4 Dec 2017
2
Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again
The IRS challenged Amazon's valuation method, claiming that Luxco's buy-in payment was not arm's length.
United States
31 Mar 2017
3
ジョーンズ・デイ・アラート:外資系企業も日本の移転価格文書の義務
平成28年度税制改正により、直前会計年度の連結総収入金額が1,000億円以上の多国籍企業グループには、一定の移転価格文書の作成・提出が義Ô
Japan
14 Sep 2016
4
Introduction of Stringent Transfer Pricing Documentation Requirement
A recent 2016 tax reform in Japan ("Reform") has introduced stringent Japanese Transfer Pricing Documentation Requirements.
Japan
13 Sep 2016
5
ジョーンズ・デイ・ニュースレター:Japan Legal Update - August 2016
最高裁判所(第一小法廷)は、平成28年7月1日、公開買付け後に少数株主のキャッシュ・アウトのために行われた全部取得条項付種類株式の取
Japan
31 Aug 2016
6
Tax Court Rejects IRS Transfer Pricing Approach In Medtronic
Medtronic Inc. & Consolidated Subsidiaries v. Commissioner (T.C. Memo. 2016-112) is the latest defeat for the U.S. Internal Revenue Service ("IRS") in a string of transfer pricing losses.
United States
21 Jun 2016
7
French Tax Update - Recent Case Law And Other Noteworthy Publications
Literally "not twice in the same," non bis in idem is basically a legal doctrine whereby no legal action can be initiated twice for the same course of action.
France
5 Feb 2016
8
Addressing The Tax Challenges Of The Digital Economy: BEPS Action 1 - Global Tax Update
On 16 September 2014, the OECD released the report on the tax challenges of the digital economy under its Action Plan on Base Erosion and Profit Shifting.
Worldwide
18 Sep 2015
9
Developing A Multilateral Instrument To Modify Bilateral Tax Treaties: BEPS Action 15 - Global Tax Update
The Report on Action 15 of the BEPS action plan (the "Report") was released in September 2014. The goal of Action 15 is to streamline and simplify the implementation of the other BEPS-related measures.
Worldwide
17 Sep 2015
10
Intangible Assets: BEPS Action 8 - Global Tax Update
The taxation of transactions involving intangible assets (either by licence of use or directly by their transmission) is possibly the OECD's biggest concern on transfer pricing and international tax at the moment.
Worldwide
17 Sep 2015
11
Country-By-Country Reporting And Global Master Files: OECD BEPS Action 13 - Global Tax Update
The OECD's recent recommendations with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises of all of the OECD's BEPS proposals.
Worldwide
17 Sep 2015
12
Countering Harmful Tax Practices: BEPS Action 5 - Global Tax Update
Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates.
Worldwide
17 Sep 2015
13
French Tax Update - 2015 Finance Law, 2014 Amending Finance Law, And Macron Draft Law
The Finance Law for 2015 and the Amending Finance Law for 2014 have now been enacted by the French Parliament and reviewed by the Constitutional Court.
France
12 Jan 2015
14
OECD Releases First BEPS Recommendations To G20 In Accordance With Action Plan
As a part of the OECD/G20 project to combat base erosion and profit shifting, the OECD released the first set of reports and recommendations on September 16, 2014.
Worldwide
9 Oct 2014
15
French Tax Update - Proposed Changes To The EU Parent–Subsidiary Directive, Q2 Noteworthy Publications, And FATCA And BEPS Updates
This update will look over changes to the EU Parent–Subsidiary Directive, recent advisory opinions issued by the Committee, recent case law, and other issues.
France
4 Jun 2014
16
New Decree Expands The Scope Of The International Ruling Procedure
The main area of application is transfer pricing, in particular advance pricing agreements.
Italy
12 May 2014
18
China May Tax Indirect Transfer Of Shares In Chinese Companies
On December 10, 2009, the State Administration of Taxation issued the Notice on Strengthening the Administration of Corporate Income Tax Concerning Equity Transfer for Nonresident Enterprises, Guo Shui Han [2009] No. 698 (the "Notice").
China
5 Jan 2010
19
Transfer Pricing Of Intangibles
The development, transfer, and licensing of intangibles are part and parcel of cross-border transactions among related parties. The allocation of costs and revenues, risks and chances, has a fundamental impact on the tax liability of multinational companies.
Germany
 
16 Oct 2009
20
China´s New Transfer Pricing Implementation Rules
On January 8, 2009, the State Administration of Taxation ("SAT") issued the Implementation Rules for Special Tax Adjustments (Trial), Guo Shui Fa (2009) No. 2 (the "Rules").
China
26 Jan 2009
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