Weekly transfer pricing roundup – 20 March 2017

As you probably know already, the deadline for the comments on the draft toolkit assisting developing countries in transfer pricing analyses has been extended to 7 April 2017. It seems it wasn’t just me who had a huge pile of readings and couldn’t get to all the commenting.

MNE Tax published an article last week which provides comments on the draft tool kit from Andrew Hickman dealing with:

  • Broadening the search process
  • Transfer pricing comparables & geography
  • Low-risk activities
  • Economically significant financial ratios
  • Classification codes
  • Order of screening criteria
  • Profit splits
  • Comparable allocation
  • Internal arrangement
  • Transfer pricing safe harbours
  • Risk & safe harbours

Some great points in the article so make sure you read it. Otherwise the following is worthwhile a read:

Norwegian shipowners reject OMSA tax evasion claims (OSJ)

“The Norwegian Shipowners Association has rejected claims by the Offshore Marine Services Association (OMSA) in the US that Norwegian owners of offshore construction vessels operating in the Gulf of Mexico are engaged in tax evasion.

As highlighted recently by OSJ, US Customs & Border Patrol (CBP) recently announced its intent to revoke several letter rulings that were said to be ‘inconsistent’ with the Jones Act. In documents provided to OSJ, OMSA claims earlier rulings “allowed foreign vessels using cheaper foreign labour” that pay “little or no taxes in the US or in their home jurisdictions” to stifle US maritime investment and job creation…”

Rollback provision in new DTAA makes it less taxing for Korean firms in India (The Hindu Business Line)

“… Experts said the clarification will help multinational companies operating from Korea. “The extension of roll back benefits can be seen as a move to assuage corporates such as LG, Samsung who have been stuck in long drawn transfer pricing litigation,” said Amit Agarwal, Partner, Nangia & Co.

The CBDT had received a number of queries on the inclusion of a rollback provision…”

Last point to mention is that Italy has introduced country by country reporting for MNEs with consolidated revenue of over 750mil Euros.

What are your thoughts?

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