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Transfer Pricing Express
2018 year-end edition
In our latest edition of TP Express, we outline details and insights into the latest OECD, EU and domestic transfer pricing developments which we hope you will find insightful. Included in our current issue are:
- Analyses of the latest OECD discussion drafts on Financial Transactions
We discuss and provide insight on some key points covered in the OECD non-consensus discussion Draft on Transfer Pricing of Financial Transactions .
- Analyses of the latest OECD guidance on Profit Splits, Hard to Value Intangibles and Attribution of Profits to Permanent Establishments
Discover our insights as we reflect on the recent guidance published by the OECD in regards to Profit Splits, Hard to Value Intangibles and the Attribution of Profits to Permanent Establishments
- Ireland’s Peer Review Report on Action 14 of the BEPS Project issued by the OECD
The OECD recently published its Peer Review Report on Ireland. The Report evaluates the country’s implementation of minimum standards under Action 14 of the OECD’s BEPS project, related to tax dispute resolution mechanisms. In this article, we discuss the four key areas as set out in the Peer Review Report.
- Global mutual agreement procedure (MAP) statistics for 2017
The OECD published MAP statistics for the 2017 reporting period available in October 2018. The report covers opening and ending inventory of MAP cases for 2017, the number of new MAP cases initiated, the number of MAP cases completed, cases closed or withdrawn, and the average cycle time for cases completed, closed or withdrawn cases.
- European advance pricing agreements (APA) statistics for 2016
The EU Joint Transfer Pricing Forum released details in relation to APAs within the EU for 2016. This contributes to improving the effectiveness and timeliness of dispute resolution mechanisms. The statistics set out which APA options are available to which European country and how many APA’s are in force for each country.
- Irish transfer pricing developments in 2018, including potential amendments to Irish transfer pricing law arising from The Coffey Review
During 2018, there has been a number of developments in Ireland’s transfer pricing regime that companies need to be aware of. We discuss the main developments in the Irish Transfer Pricing landscape such as The Coffey review, Transfer Pricing Dispute Resolution in Ireland and Guidelines on Low-Value Intragroup Services.
- Year-end deadlines and actions to be aware of relating to CbCR and requesting Competent Authority assistance under MAP article in double tax agreements
We provide insight into the year-end reporting deadlines for various countries in regards to the filing of CBC Reports and CBC Notifications. We further set out the deadlines to request competent authority assistance to relieve double taxation.
Our Transfer Pricing team is available to discuss any of the areas included in our publication or available to meet you as needed to discuss any transfer pricing related matter which you may have a concern about.