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   September/October 2016  
ITPJ Preview IBFD, Your Portal to
Cross-Border Tax Expertise
International Transfer Pricing Journal
 
This free e-mail service informs you about the contents of the forthcoming edition of International Transfer Pricing Journal.

Issue No. of the International Transfer Pricing Journal is now available online.

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Other publications and courses available on Transfer Pricing:
[Course]
Transfer Pricing Risk Management Implementation and Monitoring
10-11 April 2017
Amsterdam
> Read more
 
[Conference]
International Taxation Conference 2016
1-3 December 2016
Mumbai, India
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Number 5 - 2016 contains the following:
ARTICLES
International/OECD

OECD: Multilateral Instrument To Implement BEPS

Caroline Silberztein  and Jean-Baptiste Tristram

The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project deliverables include, among other recommendations, changes to the OECD Model. In order to fulfil the desire of OECD and G20 leaders to dramatically increase the pace in reforming international tax law, the OECD is introducing with the multilateral instrument an innovative tool which should allow rapid implementation of agreed treaty-related measures. The authors address the origin of and work related to this multilateral instrument, its potential contents and the outstanding issues.

International

Transfer Pricing Documentation: Evolution into Country-by-Country Reporting

Cym H. Lowell and Matthew Herrington

The OECD BEPS project has given rise to the development of standardized transfer pricing documentation requirements for OECD member and other countries. The authors address the requirements of the country-by-country reporting package and suggest a process for MNEs to undertake to develop compliance and planning procedures, including a checklist that the authors have found to be effective in working with clients.

International

WCO Approves Transfer Pricing Case Study

Joel Cooper and Monia Volpato

The authors discuss the new case study released by the Technical Committee on Customs Valuation of the World Customs Organization. The case study is a significant development, providing a practical example of how certain transfer pricing documentation can be used by customs authorities to determine whether a relationship has influenced the price when assessing customs valuation.

International

Interaction of Transfer Pricing Rules and CFC Provisions

Eter Burkadze

The author examines whether there is a need for both transfer pricing rules and CFC provisions, and what outcomes should be expected where these rules are applied concurrently. An analysis is provided of the structure known as the Double Irish with a Dutch Sandwich and the structure involving a so-called cash-box company in an operating lease arrangement. Moreover, the author considers (i) whether CFC rules can act as a backstop to transfer pricing rules and (ii) whether the application of these two sets of rules could lead to double taxation.

International

The Application of the Arm’s Length Principle to the Allocation of Joint Efficiencies within MNEs

Claire (Xue) Peng

This article attempts to address the arm’s length approach to allocating joint efficiencies within MNEs from a practical perspective, given the assumption that the arm’s length principle is conceptually accountable for the combined force of an MNE. Particularly, this article discusses the five transfer pricing methods in detail as well as real-life solutions to allocating economies of scale, a prototype of joint efficiencies, in the context of procurement activities.

International

Intra-Group Services: Issues, Solutions and Issues in Solutions

Shaptama Biswas

This article discusses the major issues faced by both taxpayers and tax authorities as regards intra-group service transactions, and analyses in detail the various simplification measures taken by tax administrations of various countries to resolve some of these issues for the taxpayers. The issues can be broadly classified as either the question whether intra-group services have indeed been provided, or, if that is the case, what should be the arm’s length price or charge for such services.

RECENT DEVELOPMENTS
Australia

Taxpayer Alert on Thin Capitalization and Internally Generated Intangibles

Anton Joseph

The Australian Taxation Office has issued Taxpayer Alert TA 2016/1 concerning entities inappropriately recognizing and revaluing intangible assets for thin capitalization purposes.

Austria

Transfer Pricing Documentation Law in Force

Sabine Bernegger and Werner Rosar

After the approval by the Austrian parliament in July 2016, the Transfer Pricing Documentation Law was published in the Official Gazette on 1 August 2016. The authors discuss the ramifications for entities doing business in that country.

Colombia

Decree on Submitting Transfer Pricing Data

Enrique Díaz Tong and Karilin Arenas Alvarado

A Decree was issued that sets forth requirements regarding the submission of transfer pricing declarations and transfer pricing documentation.

India

Developments in Transfer Pricing Regime

Vatika Bhatnagar

India recently made a significant move towards aligning its transfer pricing practices with global norms. This article will discuss those recent amendments which have been incorporated into the transfer pricing rules.

India

Master File, Country-by-Country Reporting and Local File: Law in the Making

Sunny Kishore Bilaney

In the Finance Act, 2016, the Indian government has introduced a regime regarding the country-by-country report and the master file under Indian tax law. A partial version of the proposed regime is introduced in the Finance Act, 2016. More specific rules and the format for the master file and country-by-country report will be prescribed in the future. In this article, the author reviews the proposed regime regarding the country-by-country report and the master file, and its anticipated impact on Indian taxpayers.

Russia

Draft Law on Country-by-Country Reporting

Kseniya Legostaeva and Svetlana Stroykova

The authors discuss the requirements that would be imposed by draft legislation on country-by-country reporting, as well as comments and suggestions for improvement as submitted by the business community.

CUMULATIVE INDEX
GLOBAL COVERAGE OF TRANSFER PRICING ISSUES
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