About aspect advisory

This author has not yet filled in any details.
So far aspect advisory has created 16 blog entries.

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. [...]

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 [...]

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 [...]

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 [...]

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, [...]

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 [...]

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