The Fiona Show: Hot Off the Press

Transfer pricing headlines for the week of November 16th, 2020

Panama is the 56th country to adopt BEPS Multilateral Instrument, Colombia sets a deadline on registering commodities agreements, and the ATO v Glencore saga comes to an end.

16 Nov 2020 6 min

Transfer pricing headlines for the week of November 9th, 2020

Changes to Zambia's transfer pricing, India will retain its tolerance range, and nothing is ever set in stone at the OECD.

9 Nov 2020 6 min

Transfer pricing headlines for the week of November 2nd, 2020

Bruno Le Maire pushes the OECD on global digital tax reforms, value chains somehow stayed intact through COVID, and don't judge Ecco's transfer pricing until you've walked a mile in their shoes.

2 Nov 2020 5 min

Transfer pricing headlines for the week of October 26th, 2020

Where is your greatest risk of transfer pricing audits? Which tax authority is lessening penalties? Happy birthday country-by-country reports? These questions and more answered…

23 Oct 2020 6 min

Transfer pricing headlines for the week of October 19th, 2020

The IRS only has so much sympathy when it comes to APAs in a pandemic, striking the Cayman Islands from the EU's blacklist raises some eyebrows, and the OECD global digital service tax talks suffer a major setback.

19 Oct 2020 5 min

Transfer pricing headlines for the week of October 12th, 2020

A COVID test manufacturer tests positive for tax evasion, another hold-up in COVID transfer pricing guidance from the OECD, and the EU Commission is back for round 2 in the Belgian tax aid case.

12 Oct 2020 6 min

Transfer pricing headlines for the week of October 5th, 2020

The EU Commission goes back to the drawing board on the Apple State Aid, Singapore issues its new COVID related transfer pricing guidance, and what you need to know about Hong Kong's new information request form.

5 Oct 2020 5 min

Transfer pricing headlines for the week of September 28th, 2020

Poland is back in the transfer pricing ring, the EU is inching closer to taking country-by-country reports public, and COVID means "business as usual" is over in New Zealand.

28 Sep 2020 5 min

Transfer pricing headlines for the week of September 21st, 2020

Russia and Hong Kong prove teamwork makes the dream work, Poland makes corporate income tax noise, and Belgium leans into their 'good cop' role.

21 Sep 2020 5 min

Transfer pricing headlines for the week of September 14th, 2020

The Italian Supreme Court thinks recent reforms to the EU’s taxation framework on interest and royalties between parent companies and subsidiaries to actually mean something, a big potential change on the horizon for how software payments are taxed worldwide, and France thinks the U.S. is trying to sabotage global digital…

14 Sep 2020 6 min

Transfer pricing headlines for the week of September 8th, 2020

Chile mandates transfer pricing documentation, Netflix is now in hot water with South Korea, and just because the CRA takes issue with your business restructuring doesn't mean the Canadian tax courts will.

8 Sep 2020 6 min

Transfer pricing headlines for the week of August 31, 2020

Brazil tries to crowdsource research on safe harbor rules, Airbnb comes out in favor of a "simple" global digital service tad, and Australia clamps down on thin capitalization with a tried and true method.

31 Aug 2020 6 min

Transfer pricing headlines for the week of August 24th, 2020

Ecuador straightens out transfer pricing on their chief export (bananas), the pros and cons of the profit-split method in COVID, and the bottom line on new ATO guidance on intercompany loans.

24 Aug 2020 5 min

Transfer pricing headlines for the week of August 17th, 2020

God help you if COVID-related wage subsidies are caught moving offshore, India straightens out their MAP, and Vladimir Putin has a new, foreign tax-related enemies list.

17 Aug 2020 5 min

Transfer pricing headlines the week of August 10th, 2020

The G20 is still committed to resolving Pillar One and Pillar Two proposal issues by end of 2020, what the ATO will do to keep Jobkeeper benefits out of offshore hands, and the rise of digital desk audits in the wake of COVID.

10 Aug 2020 5 min

Transfer pricing headlines for the week of August 3rd, 2020

The EU General Court lets Apple off the hook for a 13 billion euro tax bill to Ireland, what country-by-country reports tell tax authorities, and the coronavirus makes life harder for everyone (including transfer pricing practitioners).

3 Aug 2020 5 min

Transfer pricing headlines for the week of July 27th, 2020

The inside scoop on new country-by-country reporting rules from the United Arab Emirates, Germany holds its ground on DAC6 reporting deadlines while the rest of the EU moves to extend by another six months, and it's game on for a tarriff war between France and the U.S. over digital service…

27 Jul 2020 5 min

Transfer pricing headlines for the week of July 20th, 2020:

Cameco wins against the CRA again, a friendly reminder not to submit your local file via paper or email to the ATO, and the OECD hints that members will absolutely target profitable MNEs to help close budget deficits when things get back to "normal."

20 Jul 2020 5 min

Transfer pricing headlines for the week of July 13th, 2020

The UK pushes back DAC6 deadlines by six months, and a tale of two jurisdictions (Israel and Denmark) when it comes to burden of proof.

13 Jul 2020 6 min

Transfer pricing headlines for the week of June 29th, 2020

The post-COVID transfer pricing fallout in a single sentence: If tax rates don’t rise, count on more transfer pricing audits.

29 Jun 2020 6 min