Weekly transfer pricing roundup – 17 July 2017

There was a lot of movement in transfer pricing and BEPS around Africa this week. Cameroon signed the relevant MLIs to address BEPS, becoming the 70th member to sign the MLIs. The Ghana Revenue Authority (GRA) held a three day conference on transfer pricing abuse. The conference was aimed at raising awareness on the importance of the role of tax administrations in countering illicit activities. Interestingly, about 60 participants from international organisations and 16 African countries participated in the conference. The GRA also announced at this conference that it has began implementing measures to combat illicit financial flows, including BEPS measures. The Zimbabwean Revenue Authority announced that it is ahead of its collection target with transfer pricing partly contributing to this.

Furthermore, we finally have the updated version of the OECD Guidelines. The cost of downloading the updated version is about USD100 but you can read it online for free. For my readers from Azerbaijan, Azerbaijan’s Ministry of Taxes purchases Thomson Reuters tax solutions aimed at implementing tax control in the sphere of transfer pricing. As you know different tax authorities prefer different solutions, so just make sure you are aware of the local preferences, even if other’s are theoretically acceptable.

Then the French government said on Thursday it would appeal against a court ruling in Google’s favor with regard to 1.1 billion euros ($1.25 billion) in taxes. The Paris administrative court said Google, the main business of U.S.-based Alphabet, was not liable for the tax demand, in line with a court adviser’s recommendation made in June.

As a last news bite, the Czech Tax Authority disallowed losses made by a related party contract manufacturer and held that the total cost plus a mark-up should have been used. It seems the mark-up applied was the minimum of the range which is a little odd, I would have expected the lower quartile but wouldn’t be too surprised if tax authorities try the median of the range (even if the tested party is a  contract manufacturer). Further to the database comment above, the Czech Tax Authority used Amadeus and Albertina for their search.

In this transfer pricing roundup I tried more news bites, rather than full stories. Please let me know if you prefer the transfer pricing roundup this way, or the full news report?

What are your thoughts?

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