Weekly transfer pricing roundup – 13 Feb 2017

I am starting to make some headway with all my reading and the documents are very well written. So if you dreading the same pile, don’t, it is actually not as bad as it seems.

There is one special article I found this week from taxanalysts which you can find below. If you only have 5 minutes to read something, read that article first.

Lastly, I am looking into the second blog post for “a new transfer pricing perspective” – if you have any ideas please let me know. Happy reading.

Coalition urged to charge 10% royalty on offshore oil and gas projects (The Guardian)

“The Turnbull government must introduce a 10% royalty on all offshore oil and gas projects in Australia to ensure taxpayers start getting a fair return on their natural resources, the Tax Justice Network says.

The group has called for the petroleum resource rent tax (PRRT) to be overhauled, saying there were too many opportunities under its regime for offshore oil and gas companies to exploit transfer pricing, with direct impacts on PRRT credits and profits…”

As this is a proposal or maybe a request, it will still take some time before this will go through, but there is some merit in the thoughts expressed in the article. The mining resource rent tax (MRRT) was something similar that in the end didn’t really work out. But as always a fine balance must be found that the governments get their fair share of tax and that the business environment is kept competitive.

Conversations: Pascal Saint-Amans (taxanalysts)

“Shortly before he took over as director of the OECD’s Centre for Tax Policy and Administration on February 1, 2012, Tax Analysts interviewed Pascal Saint-Amans, who was then a relatively low-profile figure on the tax scene. Today, Saint-Amans has become something of a one-name celebrity, often referred to as simply “Pascal” in tax circles, thanks to his leadership on such major international tax reforms as the base erosion and profit-shifting project and automatic exchange of information.

As he marks his fifth year as the OECD’s tax chief, Saint-Amans — also known as the Silver Fox — again spoke with Tax Analysts, this time to talk at length about the OECD’s major tax accomplishments and the state of its current work, U.S. tax reform, Brexit, the European Commission’s state aid decision on Apple, and tax certainty in a new world order…”

This is a must read. I won’t do it justice by trying to summarise the articles. It covers questions around developments and also touches on BREXIT, some of the Trump concepts and the Apple case. So go read it.

Bye-bye, profit shifting? (Politico)

“The end of profit shifting as we know it? It’s been one of the major selling points for the House GOP’s destination-based cash flow tax — because it focuses more on where a product is consumed rather than where it was produced, corporations would have less incentive for inversions and offshore gaming in general.

What are your thoughts?

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