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Transfer Pricing
Austria
Schoenherr Attorneys at Law
The General Court (GC) of the European Union ruled in favour of Apple in the state aid case regarding Apple's Irish tax structure, annulling the 2016 decision of the European Commission (EC).
British Virgin Islands
Maples Group
The BVI ITA announced it is accepting electronic CbCR filings and FATCA / CRS deadline extensions.
Canada
Rotfleisch & Samulovitch P.C.
The Canada Revenue Agency (CRA) has been auditing Bayer Canada for its 2013 to 2015 taxation years since 2016.
McCarthy Tétrault LLP
On June 26, 2020, the Federal Court of Appeal dismissed the Minister of National Revenue's appeal of the Tax Court of Canada's decision that reversed ...
Borden Ladner Gervais LLP
On June 26, 2020, the Federal Court of Appeal (FCA) issued a unanimous decision upholding the decision of the Tax Court of Canada in Cameco Corporation v The Queen.
Osler, Hoskin & Harcourt LLP
In a unanimous decision, the Federal Court of Appeal upheld the Tax Court's decision that Cameco's transactions with its Swiss subsidiary were on arm's length terms and, therefore, compliant with Canada's transfer pricing rules and their underlying policy.
Gowling WLG
On June 23, two senior Canada Revenue Agency ("CRA") officials outlined a status update on tax controversy and dispute resolution at this stage of the COVID-19 pandemic.
Fasken
In January 2020, the OECD/G20 Inclusive Framework on BEPS, a group of 137 countries including Canada, endorsed a statement, which affirmed their commitment to build a global solution...
Borden Ladner Gervais LLP
Economic uncertainty produces various challenges for businesses, some of which are more obvious and urgent than others.
Borden Ladner Gervais LLP
On April 7, 2020, the Internal Revenue Service (IRS) and U.S. Treasury Department released the final regulations and additional proposed regulations under the Tax Cuts and Jobs Act.
Cyprus
Premioserve
On 2 January 2019 the Cyprus Tax department (CT) issued a circular (ΔΕ5) explaining the practice that CT will apply in relation to the documentation of a transfer pricing study.
Kinanis LLC
The Directive (EU) 2018/822 expand once more the provisions of the Directive 2011/16/EU - Directive on Administrative Cooperation (DAC).
European Union
ATOZ Tax Advisers
On 15 July 2020, in the Apple case, the EU judges (General Court) concluded for the second time in less than one year that the EU Commission failed to demonstrate that by issuing a tax ruling dealing with transfer pricing matters, ...
Jones Day
The Development: The EU General Court annulled the European Commission's decision in the Apple case, holding that the Commission did not prove that the Irish tax rulings in question...
Intertrust
With European Member States finding a political agreement over delaying the deadlines for implementation of the European Union's sixth Directive on Administrative Cooperation in the field...
Ropes & Gray LLP
This article includes commentary from tax partner and tax controversy group co-founder, Kat Gregor, on the implications of the European Union's new tax transparency rules.
Intertrust
There are just weeks until 1 July 2020 entry into application of the European Union's sixth Directive on Administrative Co-operation in the field of taxation (more succinctly referred to as DAC6).
India
Asit Mehta & Associates
As businesses get used to the "new normal", many are now beginning to ask, "What next?" In a post-covid world, for a lot of businesses, the instinct may be to conserve what they have, rather than go into expansion mode.
AMLEGALS
The most important and unsolved puzzle of transfer pricing litigation is Advertisement, Marketing & Promotion Expenses (AMP), which has no statutory law or legislation...
Nexdigm Private Limited
We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month...
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