Among the first to conclude an APA with the IRS, Indian IT company Infosys is paving the way for MNEs to seek certainty on transfer pricing issues such as attribution of profits to US operations in the wake of US tax reform.
Despite the vast majority of multinationals being ready to file their country-by-country reports by the end of the year, several countries chose to defer the filing deadline for a variety of reasons, including difficulties with the XML format.
Houthoff, the independent law firm headquartered in the Netherlands, expects to double its tax team by the end of 2018, starting with the hiring of Paulus Merks as a partner in Amsterdam.
TP Week rounds up some of the most influential transfer pricing disputes from the past year, and explores how they could evolve this year or what repercussions they could have for similar cases.