Practical issues, arm’s-length practices, business models and value chains will be included in the UN’s revised transfer pricing manual for developing countries, co-coordinator Stig Sollund tells TP Week in an exclusive interview.
In-house tax professionals have told TP Week they expect the EU’s Anti-Tax Avoidance Directive to increase the cost of intra-group financing, but few have actually made structural changes in anticipation of the rules.
German firm Warth & Klein Grant Thornton has added Christoph Kromer to its partnership. Kromer, who will be based in Frankfurt am Main, brings with him his transfer pricing and tax litigation team.
Heads of tax are turning to bilateral advance pricing agreements to help prevent reputational risk from accusations of sweetheart tax deals between taxpayers and tax authorities.
Intellectual property transfers, related-party debt, offshore marketing hubs and hybrid mismatches are some of the areas the Australian Taxation Office is focusing on now, Deputy Commissioner Jeremy Hirschhorn tells TP Week.
With only six months left before the wide-ranging EU’s Anti-Tax Avoidance Directive provisions enter into force, multinationals are advised to weigh compliance and controversy risks for cross-border tax structures across the EU.
