Tax & Accounting Blog

Brazil FTZ Extended to 2073

Brazil FTZ Extended to 2073

On Tuesday of last week, the camera of deputies of the Brazilian federal senate enacted Emenda Constitucional 83, which extends the constitutional term allowed to the Zona Franca de Manaus (Free Trade Zone of Manaus) until the year 2073. This program has operated since before the federal constitution of 1988 with the intent to develop … Read More

The UK Bareboat Charter Measure and the Arm’s Length Standard

The UK Bareboat Charter Measure and the Arm’s Length Standard

Drilling rig multinationals often place ownership of their key assets – drilling rigs – in tax haven affiliates, which often lease this property to operating affiliates at lease rate around 14 percent of the value of the rigs.  The UK government argues that these intercompany lease rates are generous and result in … Read More

IRS, United Nations Comment on the Latest Developments in Transfer Pricing for Developing Nations

IRS, United Nations Comment on the Latest Developments in Transfer Pricing for Developing Nations

Practitioners from the IRS, U.N., and Mexican Tax Administrative Services shared insights on the latest transfer pricing trends, in particular for developing nations, at the first Transfer Pricing Innovation Forum on June 10 in New York City. Transfer Pricing Updates at the United Nations. Ilka Ritter, Associate Expert in the International … Read More

Minimizing Transfer Pricing Risks with technology as APAC TP scrutiny increases

Minimizing Transfer Pricing Risks with technology as APAC TP scrutiny increases

The 2014 Golden Tax Summit Transfer Pricing Conference, held in Hong Kong, had a large presence of multinational corporations across the Taiwan, Hong Kong, and the Greater China areas.  During the conference, Thomson Reuters ONESOURCE held a workshop on how these organizations can improve their financial performance and optimize their transfer pricing compliance with local … Read More

Transfer Pricing brings global industry experts together as it continues to be center stage for multinationals

Transfer Pricing brings global industry experts together as it continues to be center stage for multinationals

This year’s IBC International Transfer Pricing Summit (TP Minds) in London continued to highlight the debate that is currently raging across the tax profession: “Base Erosion and Profit Shifting.” BEPS is the current focus of the OECD which has produced a series of reports that could have a major impact on the taxation of … Read More

Operational Transfer Pricing – Going from the Tax Provision to New Documentation Requirements

Operational Transfer Pricing – Going from the Tax Provision to New Documentation Requirements

As your CFO worked with your company’s financial auditors to prepare for the filing of your 10-K, you may have been tasked with the tax provision under ASC 740-10 (formerly FIN 48).  As a multinational corporation, your financial auditors are likely asking a lot of questions as to whether your intercompany pricing … Read More