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So far aspect advisory has created 9 blog entries.

New Zealand: Arm’s length conditions – not just prices

New Zealand: April 2019 - the Inland Revenue published final guidance related to recently amended legislation that better aligns local rules with certain OECD base erosion and profit shifting measures. The guidance comprises five reports covering: Interest limitation Hybrids Transfer pricing Permanent establishments Administrative measures The reports can be found here. With respect to the ... More

By |2019-05-14T08:34:13+00:00May 14th, 2019|Asia Pacific, Contracts|0 Comments

UK: Profit fragementation rules limits benefit of SME transfer pricing exemption

The UK allows a broad exemption from transfer pricing rules for small and medium-sized companies (SMEs) - in most situations: Small enterprises - no more than 50 staff and either an annual turnover or balance sheet total of less than €10 million. Medium enterprises - no more than 250 staff and either an annual turnover ... More

By |2019-05-07T08:32:54+00:00May 7th, 2019|Europe, SMEs|0 Comments

What is transfer pricing – and what does it have to do with roller-skates?

Transfer pricing can be defined simply As we kick-off training this week for our recent new hires at Aspect Advisory, we are starting from the start - by answering the question: what is transfer pricing? Although transfer pricing can be a complex discipline, its base definition is not complicated: Transfer pricing is the pricing of ... More

By |2019-05-02T07:07:24+00:00May 2nd, 2019|Fundamentals|0 Comments

One way to mitigate risks associated with key transfer pricing personnel leaving the company (and taking their knowledge of the issues with them)

Tax audits can be difficult enough without facing a situation where the tax team that was in place at the time the tax returns were prepared have since moved on. We had a client reach out to us this week who is in the beginning stages of a tax audit of the group's Italian operations. ... More

By |2019-04-30T20:32:33+00:00April 30th, 2019|Audits, Documentation|0 Comments

EUJTPF Issues Report on the Application of the Profit Split Method in the EU

The EUJTPF recently issued a report in which it hoped to clarify key concepts under which the profit split method may be used and on what basis to split the relevant profits. The EU Joint Transfer Pricing Forum, is an entity that assists and advises the European Commission on transfer pricing tax matters.  Source: EUJTPF Report ... More

By |2019-04-30T07:59:18+00:00April 30th, 2019|Europe, Intangibles, TP Methods|0 Comments

Luxembourg Cases Highlights Documentation Importance

Luxembourg: Recent cases highlights the importance of timely and complete transfer pricing documentation to support intercompany pricing arrangements. Source: Luxembourg Times; Alessandra Cea, Transfer Pricing Senior Manager PwC Luxembourg; Marc Rasch, Transfer Pricing Partner PwC Luxembourg In case law n °, 40348 (22 October 2018), a Luxembourg entity received a shareholder loan bearing an interest rate of ... More

By |2019-04-24T07:48:04+00:00April 24th, 2019|Documentation, Europe|0 Comments

IRS Launches Compliance Campaign for Captive Services

US: The IRS has launched a compliance campaign to ensure US multinational companies are paying their captive service providers no more than arm's length prices. Source: IRS The section 482 regulations and the OECD Transfer Pricing Guidelines provide rules for determining arm’s length pricing for transactions between controlled entities, including transactions in which a foreign ... More

By |2019-04-24T07:18:39+00:00April 24th, 2019|Benchmarking, North America|0 Comments

CIAT Developing “Sixth Method” Database

Latin America: The Inter- American Center of Tax Administrations (CIAT) is preparing a transfer pricing database for use in applying the sixth method. Source: MNE Tax By Robert Feinschreiber, Charles River Associates & Margaret Kent Transfer Pricing Consortium Ten Latin American counties are participating in this module: Argentina, Bolivia, Brazil, Costa Rica, the Dominican Republic, ... More

By |2019-04-24T06:59:39+00:00April 24th, 2019|Central and South America, Databases|0 Comments

US: What is the TCJA base erosion and anti-abuse tax (BEAT) and how does it work?

US: The BEAT, a new tax under the Tax Cuts and Jobs Act, limits the ability of multinational corporations to shift profits from the United States by making deductible payments to their affiliates in low-tax countries. Source: Tax Policy Center Over the past several decades, US multinational corporations have used a variety of techniques to ... More

By |2019-04-22T08:44:27+00:00April 18th, 2019|North America|0 Comments