Transfer Pricing Highlights – February 2014

Thomson Reuters Tax & Accounting Newsletters, ONESOURCE March 5, 2014

Welcome to the February edition of the ONESOURCE Transfer Pricing Newsletter, your monthly source for the latest transfer pricing news. Each edition will feature articles and insight to keep you apprised on current events in the transfer pricing industry, as well as exciting things we are working on at Thomson Reuters ONESOURCE.

We hope you find this piece informative and enjoyable! If there is anything you would like to see featured or addressed, please contact us.

WHAT’S NEW

Watch the Video – Coverage from TP Minds Americas Summit

Last week, the ONESOURCE Transfer Pricing team attended IBC’s TP Minds Americas Transfer Pricing Summit at the Biltmore Hotel in sunny Miami! This two-day event was packed with insights from transfer pricing practitioners on a variety of topics that are top of mind for the New Year. Watch our event recap video below!

TRANSFER PRICING AUDIT ROADMAP NOW AVAILABLE

The IRS recently released its Transfer Pricing Audit Roadmap with the objective of providing its transfer pricing practitioners with audit techniques and tools to help them plan, execute, and resolve transfer pricing examinations in a 24-month timeframe.

>>Read More

OECD – BEPS-RELATED TRANSFER PRICING DOCUMENTATION, COUNTRY-BY-COUNTRY REPORTING DRAFT GUIDANCE

The Indian tax authorities have tentatively established safe harbors for captive software contract R&D affiliates but have also sought the advice from a committee of transfer pricing experts. The safe harbor establishes a minimum markup over value-added expenses equal to 20 percent, which is seen by many as incredibly high. The following paper reports on the expert committee’s thoughts on how to establish a reasonable markup for captive software R&D providers using a TNMM approach, which begs the question of how to identify appropriate comparable companies.

>>Read More

MCDONALD’S FRANCE AUDITED BY FRENCH TAX AUTHORITY, DENIES ALLEGATIONS OF TAX EVASION

McDonald’s France said that it was subject to a "regular" French tax audit in October 2013, making it one of several major U.S. multinationals to get recent scrutiny by tax authorities in the country.

>>Read More

MEXICO PROBING SEVEN MULTINATIONALS FOR TAX AVOIDANCE, SAT OFFICIAL SAYS

McDonald’s France said that it was subject to a "regular" French tax audit in October 2013, making it one of several major U.S. multinationals to get recent scrutiny by tax authorities in the country.

>>Read More

Ask a Transfer Pricing Expert

Question: We sell the 30-day accounts receivables of our U.S. distribution affiliate to a factoring affiliate in a low tax jurisdiction at a 2% discount. In light of the win by the Canadian Revenue Agency in McKesson Canada v. The Queen, what implications do you think this decision has on how we should go about documenting the arm’s length nature of our intercompany factoring policy?

Click here to see the answer

 

Upcoming Events

End to End Transfer Pricing Technology with Thomson Reuters ONESOURCE
Date: Tuesday, Mar 25, 2014
Time: 11:00 AM – 12:00 PM ET

TP Minds International
March 11, 2014 – March 12, 2014
London, UK

TEI Midyear Conference
March 23, 2014 – March 26, 2014
Washington, D.C.