The Fiona Show: Hot Off the Press

Transfer Pricing headlines for the week of March 23rd, 2020

The world asks the Supreme Court to rule on Altera vs. the IRS - and the tech sector asks them to rule in favor of Altera, the OECD's 2020 review of country-by-country reporting arrives, and get brace yourselves for Belgian transfer pricing audits

23 Mar 2020 5 min

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

Tips for handling your transfer pricing in the time of COVID-19, South Africa is onto profit-shifting MNEs, and Facebook's fight with the IRS could change cost-sharing arrangements as we know them.

16 Mar 2020 5 min

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

Belgium kicks its crackdown on base erosion and profit shifting into high-gear, Turkey *finally* institutes documentation requirements, and the IMF’s Michael Keen tells the International Fiscal Association that the arm's length principle's days may be numbered.

9 Mar 2020 5 min

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

There's a bill to make country-by-country reports public in the House of Representatives, there's a bill to block high-tax exemptions from GILTI in the Senate, and the G20 puts its thumb on the scales in favor of Pillars One and Two.

2 Mar 2020 4 min

Transfer pricing headlines the week of February 24, 2020

The EU deems the Caymans a lost cause, Altera and the IRS head to the Supreme Court, and transfer pricing tops Spain's tax agenda this year.

24 Feb 2020 5 min

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

The ATO is coming for intangible assets, the golden arches find themselves in Brazil's crosshairs, and the OECD's digital tax solutions see signs of global support.

17 Feb 2020 5 min

Transfer pricing headlines for the week of February 10th, 2020

PUMA's Swedish subsidiary pays for fumbling their FAR analyses, the OECD Inclusive Framework asks if country-by-country reports go far enough, and are questionable intra-company transactions keeping you up at night?

10 Feb 2020 4 min

Transfer pricing headlines, the week of February 3, 2020

The Dominican Republic tweaks documentation thresholds and its "white list" of not-tax havens, worldwide cacophony over the future of digital service taxes, and what's a few payments from devalued stock in a foreign company jointly owned between family? Danish Tax Court says: a controlled transaction.

3 Feb 2020 4 min

Transfer pricing headlines the week of January 27, 2020

Colombia sets deadlines for documentation, the OECD tells an an international tax conference that the Pillar One and Two trains have left the station, and Royal Dutch Shell bares their 2018 country-by-country report for all the world to see.

27 Jan 2020 5 min

Transfer pricing headlines for the week of January 20th, 2019

The Italian DST goes into effect, Brazil's lagging way behind on MAP requests, but at least you can count on Finland trying to make transfer pricing easier this week.

21 Jan 2020 4 min

Transfer pricing headlines for the week of January 13th, 2019

Warning: a draft for a new German tax law could turn transfer pricing in the country on its head, South Korea (makes it look like they) simplified their refund process, and the OECD walks back requirements that countries share local files to meet Action 13 minimums.

13 Jan 2020 4 min

Transfer pricing headlines for the week of January 6th, 2020

Turkey's DST submits to a higher power, inside the EU VAT system overhaul, and Georgia's decree 366 leans harder on 2017 OECD rules.

6 Jan 2020 5 min

Transfer pricing headlines for the week of December 16th, 2019

The IRS releases final regulations on the BEAT, the latest EU effort to make country-by-country reporting public fails, and a closer look at Colombia's new permanent residence guidance.

16 Dec 2019 6 min

Transfer pricing headlines for the week of December 9th, 2019

Steve Mnuchin pulls the chair out from under the same OECD Pillar One proposals he was advocating for at the last G20 summit, then the bickering begins over Pillar Two, and the IRS asks the Supreme Court to skip hearing SIH's appeal in a $377 million payout for unpaid taxes…

9 Dec 2019 5 min

Transfer pricing headlines for the week of December 2nd, 2019

Ireland doesn't want to count its corporate tax revenue chickens just yet, and the latest in the global digital service tax drama: no one knows what to make of Pillar One reforms and a closer look at Amazon's hot take on the multilateral solution.

2 Dec 2019 6 min

Transfer pricing headlines for the week of November 18th, 2019

BHP pays up $390 million to the ATO, the Ninth Circuit Court rules against Altera, and India is not feeling the OECD's multilateral solution while developing countries cheer their counter offer.

18 Nov 2019 7 min

Transfer pricing headlines for the week of November 11th, 2019

The OECD leaves a very passive-agressive refridgerator note for all of you who can't seem to get your CbC reporting right, how the EU Council annexes shame tax havens into cleaning up their act, and it looks like the list of countries adopting unilateral digital service tax regimes is about…

11 Nov 2019 6 min

Transfer pricing news for the week of November 4th, 2019

Don't look to Bulgaria for a relaxed transfer pricing regime anymore, the G24 gives their two cents on a multilateral digital services tax, and tune in to find out if you meet Hong Kong's CbC report threshold.

4 Nov 2019 5 min

Transfer pricing headlines for the week of October 28th, 2019

Koalas, kangaroos, and the ATO's new simplified transfer pricing record keeping standards. Oh my?

28 Oct 2019 5 min

Transfer pricing headlines for the week of October 21st, 2019

The latest on the Philippines' August 29 Memorandum, and more European countries cross the digital services tax Rubicon.

21 Oct 2019 5 min