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Searching Content indexed under Transfer Pricing by Duff and Phelps ordered by Published Date Descending.
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2
OECD Releases Program For Reaching Consensus On Taxation Of Digital Economy
The tax challenges of the digitalization of the economy were identified as a primary area of focus in the 2015 BEPS Action 1 Report.
United States
17 Jul 2019
3
LB&I Keeps Transfer Pricing Examination Process Current
Review of the applicable guidance for these approaches can assist with taxpayer's own assessment of risk and documentation planning for the current year.
United States
17 Jul 2019
4
Mongolia Adopts OECD's Three-Tiered Transfer Pricing Documentation
Following the announcement that it has joined the Inclusive Framework on BEPS, the Mongolian Parliament has revised its transfer pricing regulations contained in General Taxation Law ("Revised GTL") and associated guidelines, ...
Mongolia
16 Jul 2019
5
Dispute Between IRS And Medtronic Over IP Valuation Heading Back To Court
The Medtronic case is slated to head back to court in April of 2020 in accordance with an order from the tax court.
United States
16 Jul 2019
6
TP Minds Holds Its First Canadian Transfer Pricing Conference
The inaugural TP Minds Canada conference was held on June 11-12, 2019 in Toronto, Canada.
Canada
16 Jul 2019
7
Singapore Guidance On Commodity Marketing And Trading
On May 24, 2019, the IRAS released the transfer pricing guidelines for commodity marketing and trading activities, which outlines various factors that may affect the economic value attributed to such activities.
Singapore
16 Jul 2019
8
Ninth Circuit Appellate Court Overturns Tax Court In Altera Case
On June 7, 2019 the Ninth Circuit released their decision on the appeal
United States
8 Jul 2019
9
IRS LB&I Announces Captive Services Providers Campaign
On April 16, 2019, the Internal Revenue Service Large Business and International division released an overview of three new compliance campaigns, including a captive services providers campaign.
United States
5 Jul 2019
10
New Zealand's Revised International Tax And Transfer Pricing Guidance
A summary of the most significant changes is outlined below.
New Zealand
4 Jul 2019
11
EU And Google Set Court Date On Hungary Advertisement Tax
Below is a high-level timeline summarizing developments associated with Hungary's Advertisement Tax.
Worldwide
4 Jul 2019
12
The OECD Releases 2017 Full Version Of Model Tax Convention
The document is intended to be used as a starting point for tax treaty negotiations between jurisdictions.
United States
4 Jul 2019
13
Malaysia's Special Program For Voluntary Disclosure
The IRBM introduced the Special Program for Voluntary Disclosure to encourage taxpayers to voluntary disclose underdeclared income, overclaimed expenses, reliefs, deductions and rebates.
Malaysia
3 Jul 2019
14
The OECD's Recent Efforts On Measuring And Understanding Tax Morale
On April 10, 2019, the OECD invited interested parties to provide comments on its draft working paper "What is driving tax morale – Public Consultation Document".
United States
3 Jul 2019
15
ATO Issues Draft Guidance On Thin Capitalization Arm's Length Debt Test
This will include a schedule outlining risk indicators for the application of the ALDT.
Australia
15 May 2019
16
Updates For Hong Kong Country-by-Country Reporting Framework
Consistent with the OECD framework, the IRD will also be participating in automatic exchange mechanisms designed to facilitate the exchange of CbCRs between countries.
Hong Kong
15 May 2019
17
Digital Tax Update: U.S. Legislators React To Unilateral Digital Tax Proposals
The French government estimates that the DST would raise approximately 500 million Euros per year.
United States
15 May 2019
18
United Nations Issues Draft Guidance On Financial Transactions, Profit Splits And Risk Assessment
It is Duff & Phelps' understanding that the OECD's draft is also in the process of being finalized and will likely be made available this year.
Worldwide
13 May 2019
19
IRS, Amazon Dispute Over Definition Of Intangibles
The IRS is requesting that the Court of Appeals for the Ninth Circuit remand the U.S. Tax Court's decision.
United States
13 May 2019
20
Transfer Pricing Times: IRS Advance Pricing And Mutual Agreement Program Releases Annual Report
On March 1, 2019, the APMA program announced the introduction of a new Excel-based model which taxpayers that are seeking an APA may be required to complete as part of the APA process.
Worldwide
9 Apr 2019
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