Blog Articles: International

New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles

Guy Sanschagrin | January 25, 2018

The Tax Cuts and Jobs Act of 2017 (the Act) brought sweeping changes to the international tax landscape, including the transfer pricing arena. Intangible property is at the core of many of these changes. The impact of the new provisions generally furthers the trend of transfer pricing becoming more prescriptive, placing additional strain on and creating potential contradictions with the arm’s length standard, and may have the unintended consequence of creating double-taxation for U.S. Multinationals (MNCs) – situations in which U.S. MNCs may be taxed more than once on the same income. So while the Act lowered the headline tax rate to 21 percent, it also broadened the base that will be taxed, with the result that the Act’s effect on each company’s tax bill will be determined by the company’s specific facts and circumstances.

Master File / Local File Transfer Pricing Documentation FAQs

Kash Mansori | March 23, 2017

A client recently asked me to explain the “Master File / Local File” (“MF/LF”) system of transfer pricing documentation that is being adopted by an increasing number of countries. So I thought that there was no time like the present to put together a basic overview of this increasingly common format for assembling and organizing an MNE's transfer pricing reports.

Apple, the EU, and Country by Country Reporting

Kash Mansori | February 01, 2017

The story of Apple Inc. and the European Commission is well known by now. Back in August of 2016 the EU’s Competition Commission announced their ruling that Ireland had given Apple an unfair sweetheart deal allowing it to pay less tax in Ireland than it should, and ordered Ireland to send Apple a €13 bn bill for back taxes and interest during the period 2003-14. For their part, Ireland and Apple both have said that they intend to fight the ruling...

Country by Country Reporting Update

Kash Mansori | June 14, 2016

The trickle of countries incorporating Country-by-Country Reporting (“CBCR”) requirements into their tax codes has grown into a steady stream. In the past month upcoming legislative or administrative provisions pertaining to CBCR were announced in Austria, Belgium, Germany, Sweden, Switzerland, and Bermuda, the European Parliament approved new CBCR legislation governing the EU, and it was revealed that China would formally establish its own CBCR requirements later this year. Meanwhile, the IRS is expected to release its own draft CBCR requirements by the end of June...

The Economist Falls for Formulary Apportionment

Kash Mansori | February 04, 2016

Last week The Economist devoted one of its leaders to the topic of transfer pricing. From the January 30th issue...

BEPS - What It All Means

Kash Mansori | October 29, 2015

It seems that we’ve more or less reached the end of the first chapter of the BEPS saga. Earlier this month the OECD released the final set of BEPS reports, capping off two years of work to remake the world’s ad-hoc system of international corporate taxation...

The Quantera Global Connection

Kash Mansori | September 22, 2015

Earlier this month I had the good fortune to join other members of WTP’s transfer pricing team in Basel, Switzerland, where we participated in the annual meeting of the Quantera Global transfer pricing alliance. WTP is one of two US-based members of the Quantera Global Alliance (the other being Base Firma, which has exceptional transfer pricing expertise covering Latin America), and over the past year we at WTP have had the pleasure of working with many of our alliance colleagues around the world...

Transfer Pricing and the Regulatory Climate in India

Kash Mansori | March 06, 2015

Transfer Pricing was discussed in a presidential summit between U.S. President Barack Obama and Indian Prime Minister Narendra Modi in January. India and the United States have agreed on a broad framework for resolving transfer pricing disputes involving American companies.

The EU Commission’s Problematic Reasoning on Amazon

Kash Mansori | January 16, 2015

The EU Commission views Luxembourg's tax treatment of Amazon as a violation of EU competition rules.

There Must Be a Better Way. Right?

Kash Mansori | December 04, 2014

Is there a better way to determine where a company should be taxed than using the arm's length standard?

The Most Aggressive Tax Authorities in the World?

Kash Mansori | November 20, 2014

India's tax authorities lose transfer pricing court ruling.

Attacking the Cash Box

Kash Mansori | November 12, 2014

U.S. Treasury Department looking to end cash box arrangements.

Simplifying the Rules. A Bit.

Kash Mansori | November 11, 2014

The OECD's discussion on low value-adding intra-group services and transfer pricing.

German Wishes for Irish Taxes

Kash Mansori | October 30, 2014

Ireland is a popular country for its low corporate tax rate and it makes it tough for other European countries to compete for these dollars. Why doesn't Germany ask Ireland to raise the rate in exchange for assistance.

What Is This ‘BEPS’ Thing, and Should I Care?

Kash Mansori | October 24, 2014

The OECD is looking into how the international tax landscape for corporations should evolve.

Fighting Over Tax Revenue in Europe

Kash Mansori | October 17, 2014

Taking another look at how multinationals are using corporate structures in Europe.

A New Arena for Transfer Pricing Disputes

Kash Mansori | October 13, 2014

Scrutiny of transfer pricing arrangements.