A Swedish court has ruled on timelines for information used in benchmarking searches in a case involving The Absolut Company, which produces Absolut Vodka. The court concluded, supported by the OECD TP Guidelines, that looking at data from years after the year under review would constitute hindsight and would not be accepted.
As the US tax reform bill passes its final stages in Congress, a new transfer pricing regime becomes apparent with the establishment of a new base erosion and anti-abuse tax (BEAT) and a controversial new tax on intangibles (GILTI).
If the EU’s proposal to introduce virtual permanent establishments materialises, it could mean higher tax bills not only for tech companies such as Apple, Amazon and Facebook, but also for non-digital companies.
With the BEPS project increasingly reining in countries’ ability to offer tax incentives, governments advocate a low corporate income tax rate as pivotal for attracting business. However, corporate stakeholders, economists and academics in the transfer pricing community point to the diminishing value of corporate income tax.
Reforming the arm’s-length principle was identified as a priority in the BEPS project, but transfer pricing rules are now more complex than ever. Does the post-BEPS era require a reform of the arm’s-length principle?
Australia has urged tax authorities across the globe to begin scrutinising the ‘treasure trove’ of documents from the Paradise Papers. Commissioner Chris Jordan has set his sights on intermediaries which facilitate tax avoidance and evasion.
