In this edition of Transfer Pricing Times, we present insights on recent transfer pricing developments from around the globe.
In “Answers to Practical Questions About the Pillar One Blueprint”, we review the main elements of the OECD’s Pillar One Blueprint and how multinational companies can assess its potential impact on tax liabilities and double taxation.
In “Expansion of India’s Equalisation Levy to Impact More Tech Companies”, we discuss the recent expansion of the Indian Tax Authority’s Equalisation Levy that was implemented to address tax issues created by the digital economy.
In “New Regulations on Transfer Pricing Documentation and Penalty Protection Regime in Italy”, we outline the key changes for companies to consider from the provision by the Italian Revenue Agency which amended the 2010 transfer pricing documentation requirements.
In “Canada’s Supreme Court Declines to Hear Cameco Case Appeal; Recharacterization Attempt Fails”, we examine the Crown’s losses in the Cameco and AgraCity court cases that tested Canada’s transfer pricing recharacterization rules.
Finally, in “President Biden and Senate Democrats Propose Revisions to U.S. Tax Code”, we provide an overview of recent proposals for reforming U.S. tax regulations.
We hope that you will find this and future issues of Duff & Phelps, A Kroll Business, quarterly transfer pricing newsletter informative.
Answers to Practical Questions About the Pillar One Blueprint
by Simon Webber
Expansion of India’s Equalisation Levy to Impact More Tech Companies
by Salim Vagh
New Regulations on Transfer Pricing Documentation and Penalty Protection Regime in Italy
by Enrico De Angelis
Canada’s Supreme Court Declines to Hear Cameco Case Appeal; Recharacterization Attempt Fails
by Matt Billings
President Biden and Senate Democrats Propose Revisions to U.S. Tax Code
by Zachary Held
Valuation and consulting for financial reporting, federal, state and local tax, investment and risk management purposes.
Comprehensive transfer pricing advisory covering compliance, planning, controversy and implementation.
Transfer Pricing Controversy/Expert Services
Economic review, analysis of proposed settlements and objective expert testimony in litigation.
Transfer Pricing Valuation Services
Value a range of intangible property, functions and other interests for tax purposes.
Financial Transactions Transfer Pricing Services
Valuation and strategic implementation of financing arrangements covering loans, guarantees, cash pools and preferred equity.
Transfer Pricing Global Compliance Services
Global and local transfer pricing documentation, benchmarking and Country-by-Country reporting compliance.
Transfer Pricing Operational Services
Enhance internal strategic reviews, implementation strategies and assistance in evaluating planning structures and third-party tools.
Transfer Pricing Strategic Planning Services
Duff & Phelps’ Transfer Pricing Strategic Planning Services are designed to assist companies when setting up new operations, integrating new acquisitions and divesting existing business lines.