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

Switzerland Supports OECD Multilateral Discussions on Digital Tax Measures

Switzerland Supports OECD Multilateral Discussions on Digital Tax Measures

BEPS, Blog, Checkpoint August 14, 2018

On July 22, 2018, the Swiss Federal Council (a seven-member executive council of the federal government) issued a press release regarding discussions by the Swiss representative at the G20 annual meeting of finance ministers and central bank heads in Argentina on digital tax developments. Switzerland agrees that multilateral discussions on these developments led by the OECD … Read More