Weekly transfer pricing roundup – 14 August

news-1074604_960_720I had the privilege to provide some input into an interesting article about “BEPS goes global and local: What it means for operations in non-adopting markets” The article starts as follows:

“With more than 80 countries now having agreed to adopt at least the minimum elements of the BEPS Action Plan, there’s no getting around BEPS. But partial or modified application in different local markets is creating an even more complex patchwork of requirements than before. A lack of sophisticated tax management capabilities can result in competing demands and a greater risk of tax disputes and double taxation that follows. So what are the complexities facing your business, why are the risks increasing and how can you manage the impact?”

If you would like to read the full article click here and feel free to ask me questions on the blog or get in touch as per the contact details on the article.

And in other news:

Canada issues proposed legislation on country-by-country reporting (PwC)

On July 29 2016, Canada’s Department of Finance released draft legislative proposals for public comment that would implement CbC reporting requirements proposed in the 2016 federal budget. The proposed amendments mirror the guidance issued by the OECD under BEPS Action Point 13 and would be applicable for fiscal years beginning after 2015.

The draft legislation maintains the Euro750 million threshold proposed by the OECD and introduces standard administrative penalties for gross negligence or failure to file the CbC reporting form. It also refers to a prescribed form for filing, although this has not yet been released…

Russia to Adopt Country-by-Country Reporting From 2017 (BNA)

The Russian government has a strong intention to require multinational companies to report taxes and profits by country of operation from 2017 and provide for voluntary disclosure of that information from 2016, three EY practitioners said…

The reports would have to be prepared within 12 months of the end of the financial year for which consolidated financial statements are prepared. The draft law also provides for reports to be submitted on a voluntary basis for financial years prior to 2017…

The master file and local file aren’t yet required in Russia, but they may be introduced as “a next natural step at a later point, once the country-by-country reporting requirement is enforced,” they said…

CE Industry Facing ATO Crackdown (Channelnews)

Several large consumer electronics companies who operate their Australian operations via a Singapore sales hub are facing a new ATO crackdown which could see them forced to pay millions in tax, if they do not comply with new Australian tax rulings.

Channelnews understands that several companies CE companies operate via Singapore into the Australian market.

Among the companies that operate via Singapore Apple, Toshiba, Hewlett-Packard, Sony, Microsoft and several large TV manufacturers.

In the past companies like Sony have been fined over $30 million in tax related crackdowns…

New watchdog to nose out MNCs’ profit shifting (The Financial Express)

Government’s revenue authority (Bangladesh) is raising a new watchdog team styled ‘resource pool’ to nose out profit shifting by multinational companies from Bangladesh illegally.

Officials said the National Board of Revenue (NBR) is forming the strong surveillance team with best of the bunch of taxmen under the transfer-pricing law to check the flight of funds…

Customs, SBP sign MoU for issuing e-forms for imports (The Nation)

The State Bank of Pakistan (SBP) and Customs Department of the Federal Board of Revenue (FBR) on Tuesday signed a Memorandum of Understanding (MoU) for issuing electronic forms for imports to curb the menace of under-invoicing and transfer pricing…

The use of E-Form will curb the menace of under-invoicing and transfer pricing in addition to integrating the foreign exchange accounting system of the SBP with Customs clearances…

Group urges IRS action against drug company (The Hill)

The liberal group Americans for Tax Fairness (ATF) is urging the Treasury Department and Internal Revenue Service (IRS) to take action against drug company Gilead Sciences because it has allegedly been shifting income offshore to avoid taxes.

“We urge the administration to bring the full force of your enforcement capabilities against Gilead to collect the tax dollars that rightfully belong to the American people,” ATF said Wednesday in a letter to Treasury Secretary Jack Lew and IRS Commissioner John Koskinen…

What are your thoughts?

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