In a recent conference, acting head of transfer pricing for the Russian Federal Tax Service, Vladimir Golishevsky, discussed when it is suitable for taxpayers to rely on OECD guidelines.
Golishevsky’s statement demonstrates that, while OECD guidelines are becoming widely used, many countries - including Russia - still consider domestic policies to be more suitable in some cases.
The IRS transfer pricing audit roadmap was created to improve the efficiency and consistency of transfer pricing audits, placing greater emphasis on the process of individual cases.
China has demonstrated a certain degree of resistance towards the OECD guidelines and adopting international policies but it is beginning to show signs of acceptance.
On July 23, Michelle Levac, chair of Working Party No 6, announced that the revised chapter on intangibles, to be released in September, will not be final guidance.
The European Commission (EC) announced recently that it has opened three in-depth investigations into supposed sweetheart deals between the tax authorities of Ireland, the Netherlands and Luxembourg with Apple, Starbucks and Fiat. The investigations are looking into whether the deals comply with EU rules on state aid.
Inversion deals between companies such as Medtronic and Covidien, and failed attempts such as Pfizer’s desired takeover of AstraZeneca, have brought inversion transactions to the forefront of global tax issues. While the US government argues that inversion deals are anti-competitive, many taxpayers feel they are faced with an unappealing US tax system and have no choice but to look elsewhere.
