Tax & Accounting Blog

CJEU Denies the Hamamatsu Photonics Retroactive Transfer Pricing Adjustment

CJEU Denies the Hamamatsu Photonics Retroactive Transfer Pricing Adjustment

Co-written by J. Harold McClure and Yanan Li Hamamatsu Photonics is a Japanese manufacturer of various optical devices, which are sold in Europe by Hamamatsu Photonics Deutschland GmbH (HPD). HPD obtained an Advance Pricing Agreement (APA) with the German and Japanese tax authorities that targeted an operating margin. On December 20, 2017, the Court … Read More

Argentina and Brazil Driving Fast on the Automotive Speedway

Argentina and Brazil Driving Fast on the Automotive Speedway

The automotive industry within Mercosur (economic bloc composed of Argentina, Brazil, Paraguay and Uruguay), is undergoing important changes within the Mercosur countries. For Brazil, progress is being made through the implementation of Plan Rota 2030, which aims to stimulate the modernization of the industry and the energy efficiency of automobiles; also serving as replacement of … Read More

Has Article 1 of the TFA Become a Casualty of Donald Trump’s Trade War?

Has Article 1 of the TFA Become a Casualty of Donald Trump’s Trade War?

As discussed in an earlier post (Shouldn’t Governments be Doing more to Fulfill the Promise of the TFA Article 1?), the Trade Facilitation Agreement mandates that each World Trade Organization member promptly publish tariff and regulatory trade information in an “easily accessible manner”. This requirement is being tested to its limits … Read More

Reacting to Customs and Border Protection’s (CBP) Ruling Changes

Reacting to Customs and Border Protection’s (CBP) Ruling Changes

Importers today are engaged in complex supply chains where products cross borders multiple times to take advantage of special duty savings programs, free trade agreements, and other manufacturing cost considerations.  It is important to stay on top of the rules for allowing special duty exemptions since there are occasions when CBP will reconsider rulings previously … Read More