Transfer Pricing - MNE Tax
WEBMay 17, 2022 · July 7, 2022. In a bid to curb profit shifting, Kenya is increasing its transfer pricing documentation requirements. The recently published Kenya Finance Bill seeks to have the ultimate parent entity of a multinational enterprise group or a constituent entity of a multinational enterprise group (MNE’s), which is a tax resident in Kenya, file ...
OECD’s GloBE rules: Blending in with jurisdictional blending
WEBSep 24, 2021 · By Noopur Trivedi and Jitesh Golani. Out of the multiple crucial design elements of the global minimum tax under Pillar Two of the OECD/G20 July 1 statement, the adoption of “jurisdictional blending” for computation of effective tax rate and consequent top-up tax denotes one of the most pivotal policy choices for the global anti-base erosion …
Taxing offshore indirect transfers, the Platform’s new toolkit - MNE …
WEBJun 10, 2020 · By Francesca Amaddeo, Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland. On 4 June, the Platform for Collaboration on Tax, a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG), released its new toolkit concerning the taxation of offshore indirect transfers. Indeed, as developing countries …
Dutch intercompany financing rulings and the transfer pricing of ...
WEBSep 2, 2021 · A March 6, 2020, Supreme Court decision considered a similar issue, except the size of the intercompany financing was substantially larger (ECLI:NL:PHR:2020:102). A 2010 intercompany loan with principle equal to EUR 635 million was issued to a Dutch affiliate with an interest rate equal to 11.2 percent. The Dutch tax authority argued that …
Dutch report on international tax and transfer pricing rulings …
WEBJun 29, 2021 · By Clive Jie-A-Joen, Counsel, and Monique van Herksen, Partner, Simmons & Simmons LLP, Amsterdam. The Dutch Revenue Service’s 2020 annual report on international tax rulings published 15 June provides preliminary insight into experiences with advance pricing agreements (APAs) and other international tax rulings in the first full …
Italy’s new clarifications concerning VAT treatment of ... - MNE Tax
WEBFeb 1, 2022 · The Italian tax authority (“ Agenzia delle Entrate ”) addressed (once again) the VAT treatment of transfer pricing year-end adjustments in its response to ruling No. 884, published on 30 December 2021. The petitioner is an Italian company belonging to a multinational group, operating in the fashion industry, which controls four subsidiaries ...
Adjusted cost of goods sold as a proxy for related party ... - MNE Tax
WEBNov 14, 2017 · Adjusting cost of goods sold (COGS) to remove the effect of one-year change in inventories is important to determine the arm’s length gross profits of intercompany (related party) inventory goods transactions. Ad j usted COGS produce also a more reliable measure of the operating profits of the tested party (audited taxpayer) and …
Cameroon - MNE Tax
WEBJul 11, 2017 · Cameroon signs MLI to tackle tax avoidance by multinational enterprises. July 11, 2017. Cameroon’s Minister of Finance, Alamine Ousmane Mey, today signed the Multilateral Convention to Implement Tax Treaty Related Measures to …
US IRS releases agent training materials on transfer pricing, foreign ...
WEBThe US IRS on August 28 released IRS agent training materials on transfer pricing rules under section 482 and on foreign-to-foreign transactions under section 367(b).
Italian digital services tax takes its first steps
WEBJan 25, 2021 · By Francesca Amaddeo, Lecturer-Researcher, Tax Law Competence Centre (SUPSI), Manno, Switzerland. On 15 January, the Italian revenue agency released final guidance on the national digital services tax, provision n. 13185/2021. The Italian digital services tax, implemented by Law n. 145/2018 (as updated by Law n. 160/2019), …