Google is forcing tax authorities to grapple with transfer pricing in the digital economy in several jurisdictions as the tech giant looks to avoid paying a hefty tax bill from France.
Microsoft’s recent transfer of ownership of its New Zealand subsidiary from Luxembourg to Bermuda also coincides with Luxembourg signing on to the OECD’s multilateral instrument that promises to curb double taxation and crack down on tax avoidance.
India’s Central Board of Direct Taxes has revised the safe harbour rules of September 2013 on international transactions in an effort to curb transfer pricing audits and prolonged disputes.
Duff & Phelps has announced that BaseFirma will be joining its transfer pricing alliance, strengthening in particular the firm’s presence in Latin America.
Companies are advised to check for relevant changes to their respective domestic laws following the signing of the OECD’s multilateral instrument (MLI) by 76 countries with much fanfare on Wednesday. The rewriting of bilateral taxation treaties on such a large scale is expected to improve arbitration in tax dispute resolution and curb double taxation, but is likely to be implemented to varying degrees across jurisdictions.
A transfer pricing case involving advertisement, marketing and promotional (AMP) expenses has seen Indian tax tribunals go against recent court decisions, signalling a shift in the approach the bright line test is used to assess AMP expenses.
