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What does a case about fishing have to do with transfer pricing?
by Lisa Yashar, WTP Advisors ———- In the case Loper Bright Enterprises v. Raimondo, regarding a U.S. law governing marine fisheries management, the Supreme Court overturned the longstanding Chevron Doctrine. Its impact will be wide-reaching, providing opportunities to challenge agency interpretations of laws. This includes the treasury regulations under IRC § 482. What is the…
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The EU Commission’s Problematic Reasoning on Amazon
Read more: The EU Commission’s Problematic Reasoning on AmazonBy Kash Mansori, WTP Advisors Posted: January 16, 2015 Today the EU Commission released a document detailing its reasoning behind its decision to consider Luxembourg’s tax treatment of Amazon to be a violation of EU competition rules. The full document can be found here (pdf). The crux of the EU Commission’s argument is that Luxembourg gave…
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Featured Article – Changes to Australia’s Transfer Pricing Rules
Read more: Featured Article – Changes to Australia’s Transfer Pricing Rulesby Doug Schwerdt, WTP Advisors Transfer Pricing NEWS: An exposure draft of legislation was released on November 22, 2012, “Tax Laws Amendment (Cross-Border Transfer Pricing) Bill 2013: Modernisation of transfer pricing rules—proposing changes to Australia’s domestic transfer pricing rules,” to introduce new Australian transfer pricing rules with significant self assessment and documentation requirements. The start…
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New Ukraine Transfer Pricing Rules
Read more: New Ukraine Transfer Pricing Rulesby Doug Schwerdt, WTP Advisors Prior to 2012, Ukraine had not been overly concerned about transfer pricing issues. But recently, in the era of fiscal deficits, the Ukrainian government has been more focused on implementing transfer pricing compliance practices in accordance with OECD member countries. Transfer Pricing NEWS On December 4, 2012 the Parliament of…