OECD Pressed for More Guidance on Permanent Establishment Rules

Companies need additional guidance on the impacts of remote work on corporate taxes and the creation of taxable permanent establishments, practitioners told the OECD in comments as part of the group’s global workforce mobility project.

SentinelOne Settles IP Transfer Pricing Dispute in Israel

SentinelOne resolved its transfer pricing dispute with the Israeli Tax Authority this month regarding certain intercompany transactions between the company and its Israeli subsidiary, the company said in financial filings Wednesday.

HMRC Urges Rigorous Analysis for Transfer Pricing Compliance

Multinational groups should conduct rigorous value chain analysis for their UK entities to accurately reflect financial transactions and ensure compliance with transfer pricing rules, the UK tax authority said Thursday.

Australia Plans to Target Property Development Tax Strategy

The Australian Taxation Office is working on new guidance to crack down on related-party property development arrangements that it believes are being used to improperly defer paying taxes on project profits, potentially indefinitely.

OECD Official Previews More Guidance Under Global Minimum Tax

The OECD plans to issue a raft of global minimum tax guidance clarifying the treatment of certain businesses and accounting standards, an official said Thursday.

Latest Stories

Mountain of Big Legal Cases Faces IRS: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re checking out the growing mountain of TP cases facing the IRS this year, even amid all the budget cuts and staffing departures at the agency over the last year. And we’re following up on the EU advisory opinion on Stellantis’ case involving TP adjustments and VAT.

US Tax Carve-Out Beats Retaliation, OECD Business Rep Says

In this episode of Talking Tax, Christian Kaeser, global head of tax at Siemens AG, told Bloomberg Tax reporter Ryan Hogg that some of his European counterparts regarded the deal as “lopsided” but welcomed new permanent safe harbors that were created with input from Business at OECD, known as BIAC. Kaeser is co-chair of BIAC’s tax committee.

China Deepens PDD Probe After Fistfights With Regulators

China has broadened a probe into PDD Holdings Inc. after its employees exchanged blows with regulators, dispatching over 100 investigators from various agencies to the company’s Shanghai headquarters in recent weeks, according to people familiar with the matter.

Seeking Permanent Establishment Clarity: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at the mountain of comments the OECD got about global workforce mobility and permanent establishments. Surprise, surprise! Folks want/need more guidance. Plus, an advocate general opinion in the EU’s top court on Stellantis’ TP adjustments and VAT, and more.

Tax Developments

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Denmark Tax Agency Clarifies Permanent Establishment Rules for Nonresident Contractors Under DTA with Poland

The Danish Customs and Tax Administration Jan. 20 posted online City Court Decision No. SKM2026.40.BR, clarifying permanent establishment (PE) rules for nonresident contractors under the 2001 Denmark-Poland DTA. The taxpayer, ...

Armenia MOF Posts Synthesized Text of DTA, Protocol With Estonia in English

The Armenian Ministry of Finance Jan. 21 posted a synthesized text, in English, of the 2001 DTA and protocol with Estonia, and the Multilateral Convention to Implement Tax Treaty Related ...

Armenia MOF Posts Synthesized Text of DTA, Protocol With Croatia in English

The Armenia Ministry of Finance Jan. 21 posted a synthesized text, in English, of the 2009 DTA and protocol with Croatia, and the Multilateral Convention to Implement Tax Treaty Related ...

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