Italian Free-Guarantee Ruling Boosts Transfer Pricing Toolkit

The Italian Supreme Court’s recent acceptance of a subsidiary’s no-fee guarantee for a parent company’s loan highlights what some tax practitioners see as growing willingness by courts to accept purely economic reasons for not charging intragroup fees, at least in the area of corporate finance.

Australia Needs More Tax Power for News, TV Broadcasters Say

The Australian Tax Office needs additional tools to discourage transfer pricing by tech companies hoping to avoid paying for local news content, the country’s commercial television broadcasters say.

IRS Says Periodic-Adjustment Memo Continues Arising in Audits

An IRS legal memo on the agency’s ability to adjust a company’s profits continues to come up in audits of companies’ transfer pricing, an IRS official said Wednesday.

EU Urges Luxembourg, Malta to Bolster Tax Dodging Deterrents

The European Commission pushed Luxembourg and Malta to strengthen measures against aggressive tax planning, warning both countries they’re susceptible to companies shifting profits to low-tax jurisdictions.

OECD Clarifies Intragroup Services in Proposed Guide Update

The OECD launched a public consultation Monday focused on updating transfer pricing guidance to clarify existing principles and provide practical examples for identifying and pricing intragroup services.

Latest Stories

Indonesia Says Export Agency Will Focus on Price, Not Trading

Indonesia’s commodity export agency will focus on monitoring the price of key raw-material exports instead of intervening in trade, according to a senior official, in an apparent effort to ease industry concerns over a radical natural-resource policy introduced last month.

Tax Developments

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Netherlands Gazettes MoU Specifying Mutual Agreement Procedures Under 1976 DTA With Australia

The Dutch Official Gazette June 10 published the memorandum of understanding (MoU), signed May 28, establishing the rules and requirements regarding mutual agreement procedures (MAPs) under the 1976 DTA with ...

Romania Tax Agency Issues Draft Order on Advance Pricing Agreement Procedures, Documentation Requirements

The Romanian National Agency for Fiscal Administration June 5 issued a draft order to approve the procedures and documentation requirements for advance pricing agreements (APAs). The draft order includes measures ...

Ukraine MOF Posts Text of DTA, Protocol With Germany in Ukrainian, English

The Ukrainian Ministry of Finance June 10 posted the text, in Ukrainian and English, of the DTA and protocol with Germany, signed May 19, which will replace the 1995 DTA ...

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