Weekly transfer pricing roundup – 14 November

updateOur preparations to present at the TP Summit are in full swing and include some really interesting topics. If you want to hear more about notification requirements for CBCr (some deadlines are already by December 2016) or what royalties and services have to do with customs and transfer pricing come join me. It is going to be interesting and fun.

But for this post we shall stick to the latest developments which includes South Africa introducing transfer pricing documentation retention requirements and the former federal treasurer (of Australia) accusing BHP of stripping profits into Singapore.

By the way, I have been tracking the stats for the posts and they are always growing, thanks to you. But please don’t forget to share or like the posts if you think they are valuable to share the love.

Transfer pricing documentation now compulsory in South Africa, and more!

SARS has finalised the previous discussed draft notice which requires taxpayers to keep certain records, books of account or documents as prescribed in the notice, in terms of section 29 of the Tax Administration Act, 2011. The notice which was gazetted on 28 October 2016 requires certain taxpayers to maintain transfer pricing documentation on an annual basis, and more.

Swan urges BHP to explain tax affairs (news.com.au)

“Former federal treasurer Wayne Swan says the board of mining giant BHP Billiton must explain how the company sought to evade $300 million in Queensland state royalty payments…

The Labor MP has accused BHP of using a Singapore tax shield to smuggle profits out of Australia.

“The evidence against BHP is damning. Over a decade, they have ramped up their Singapore marketing hub to camouflage aggressive transfer pricing,” he said…”

SEC Roundup: Accenture in IRS Real-Time Audit Program (BNA)

“Accenture Plc, the world’s largest consulting firm, has entered the IRS program for continuous, real-time auditing and expects a decrease in its reserves against possible transfer pricing issues, according to filings with the U.S. Securities and Exchange Commission.

Accenture was one of 10 companies to report significant transfer pricing and international corporate taxation issues during October. An alphabetized list follows…”

The article lists the following companies with excerpts from the filings:

  • Accenture Plc
  • Bristol-Myers Squibb Co.
  • Celestica Inc.
  • Edwards Lifesciences Corp.
  • Jabil Circuit Inc.
  • Microsoft Corp.
  • Quaker Chemical Corp.
  • Rowan Companies Plc
  • Team Inc.
  • Visteon Corp.
Israel to Tax Earnings from International Money Transfers (BNA)

Nov. 7 — A multinational company based in a jurisdiction that has no tax treaty with Israel must pay Israeli taxes on its Israel-related earnings from international money transfer services, the Israel Tax Authority determined.

The ruling is set to apply to the growing number of financial service firms entering the Israeli market, if they are located in a country not covered by a tax treaty with Israel, a senior Tax Authority official told Bloomberg BNA Nov. 3.

Israeli practitioners said the small number of developed countries without such treaties and other formulas available under transfer pricing regulations will greatly limit its use.

More worrisome, they said, is the Tax Authority’s growing appetite for taxes from international transactions by foreign businesses…”

Nokian Tyres tax dispute proceeds. The Company is now finally in position to appeal to the Administrative Court (Business Wire)

“The Board of Adjustment of the Finnish Tax Administration held the reassessment decision from the Tax Administration unchanged related to additional taxes EUR 62.8 million but decreased the amount of punitive tax increases and interests from EUR 31.3 million to EUR 26.4 million concerning tax years 2007-2010. The decision of the Board of Adjustment was not unanimous…”

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