The Canada Revenue Agency (CRA) has released transfer pricing memorandum TPM-15 on intra-group services which overlooks the OECD’s proposals for a more simplified approach.
The US Multistate Tax Commission’s (MTC) Arm’s Length Adjustment Services (ALAS) programme is a response to interstate income shifting. The MTC hopes to provide state governments with a comprehensive programme to increase state transfer pricing revenues.
After investigating Caterpillar’s US tax returns, the Internal Revenue Service (IRS) is threatening to tax profits the company earned from its Swiss based subsidiary (Caterpillar SARL). Caterpillar claims nothing untoward took place and plans to challenge the IRS through the appeals process.
With the deadline for the base erosion and profit shifting (BEPS) project still some time away, governments are deliberating whether to take the issue into their own hands and act ahead of final OECD recommendations in December 2015.
The OECD’s implementation guidance on country-by-country reporting (CbCR) has done little to placate the debate between multinationals and non-government organisations (NGOs) over the degree of confidentiality required in documentation.
The Australian Taxation Office (ATO) has been accused of pushing for big corporations to conduct their own tax audits. Negative comments in the media and statements from alleged employees claim the ATO’s efforts to reduce costs will ultimately result in victory for tax cheats.
