In response to the Organisation for Economic Co-operation and Development (OECD) revisions to transfer pricing of financial transactions, the Japanese transfer pricing administrative guidelines have been reformed in Japan effective 1 April 2023. The latest revisions clarify the application of...

On 19th February, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting published its report on Amount B under Pillar 1, which intends to provide a simplified and streamlined approach to transfer pricing compliance for entities engaged in baseline...

On 9 February 2024, the Tribunal issued a ruling in the case KETAT 143 (KLR) between the appellant Beta Healthcare International Limited (Beta Kenya) and the respondent the Commissioner of Legal Services and Board Coordination (KRA). The matter in dispute...

In due course, the EU Court of Justice (ECJ) may shed some light on the VAT intricacies of transfer pricing (TP) adjustments. In Arcomet, the Bucharest Court of Appeals asked the ECJ whether the amounts included in yearly equalisation invoices...

For more information on the topic join our webinar on 17th of September. One of the most debated topics in the international tax arena is Pillar 2, the global minimum corporate tax. Alongside this, work on Pillar 1 continues at...

The financial services sector remains firmly in the spotlight of global tax authorities and prudential regulators. Whether it is HMRC in the UK or the Internal Revenue Service (IRS) in the US, understanding how money moves between regulated entities and...

For the first time, the Republic of Moldova has introduced the Tax Code provisions on transfer pricing and the arm's length principle. These measures are expected to apply from 1 January 2024, with an aim to bring local legislation closer...

In 2021, the European Central Bank (ECB) published its final guide on climate-related and environmental risks for banks. It aimed at enhancing the industry’s awareness and preparedness for managing climate-related and environmental risks. The risks mentioned are commonly related to...

Over the last decade, the Organisation for Economic Co-operation and Development (OECD) and the European Union (EU) have made significant developments regarding tax transparency regimes and the exchange of information between tax authorities.  However, these developments are being taken further...

Pillar 2, which is the Global Anti-Base Erosion Rules (GloBE) minimum tax project, and the BEFIT initiatives are considered likely to reduce some tax planning opportunities respectively at worldwide and EU levels, and thus reduce the need to address them...

Initiatives mentioned in the previous article already affect and will further affect multinational companies in a significant way. The first step for multinational companies  to consider is how to build stakeholders’ understanding of the impact these changes in domestic legislation...

The international tax landscape has undergone major changes over the past few years which is set to have a significant impact on the overall tax architecture. At both international and European Union (EU) levels, several initiatives have been pursued aimed...

With rising inflation and multiple key interest rate increases, multinational enterprises should consider reviewing the prices of their intercompany financing transactions, which may no longer align with the arm’s length principle. The quick rise in interest rates may have created...

On 7 February 2023, the UK tax authority HM Revenue & Customs (HMRC) released its Transfer Pricing and Diverted Profits tax statistics for the 2021 - 2022 tax year. The statistics clearly demonstrate that both transfer pricing and Diverted Profits...

National differences and approaches to transfer pricing are evident all over the world. In particular, tax jurisdictions in developed countries have now taken quite advanced steps in approaching complex transfer pricing situations from a technical debate perspective. Whereas in some...

Background The State Administration of Taxation (“STA”) has made a continuous effort to promote Advanced Pricing Arrangement (“APA”). On 26 July 2021, the STA issued STA Public Notice [2021] No.241 (“Bulletin 24”), which sets forth simplified procedures for unilateral APA...

Providing information on taxation in 22 Central and Eastern European (CEE) states, the latest Mazars CEE tax guide analyses long-term taxation trends and fundamental tax regime changes in each country, both now and in previous years.

The Diverted Profits Tax (DPT), or what the media have dubbed the Google tax, was introduced in 2015 to dissuade and counteract contrived arrangements used by large multinational groups that divert profits from the UK and erode the UK tax base.

Transfer Pricing Bill in Israel passes third reading in June 2022 and is approved. What are the implications for businesses in Israel? In June 2022, the new transfer pricing bill was approved. This is another step towards the Israel Tax...

Following Italy’s new transfer pricing (TP) requirements1 introduced on 23 November 2020, there has been much discussion as to whether the taxpayer may benefit from penalty protection that also covers additional withholding tax otherwise due when the Italian tax authorities...

On 14 March 2022, the OECD published a comprehensive commentary and illustrative examples of how implementing the Global Anti-Base Erosion Model Rules (GloBE rules) could look. In this blog, we discuss the GloBE rules and examine how the rules apply...

With Law No. 7338 on Turkish Tax Procedure Law (TPL) and Amending Certain Laws (“Law No. 7338”) published in the Official Gazette dated October 26, 2021, a domestic regulation was made for the first time regarding the mutual agreement procedure...

A proposed model for establishing an advance pricing agreement (“APA”) programme in South Africa (“SA”) was issued by the South African Revenue Authority (“SARS”) during December 2021. This article highlights some notable aspects of this proposed programme, by comparing it...

On 20 January 2022, the Organisation for Economic Co-operation and Development (OECD) released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG). This blog provides a summary of the revised Chapters of...

Advance pricing agreements (“APAs”) could provide taxpayers and revenue authorities with some certainty during the unprecedented times that we are living in. The African APA landscape is however underdeveloped, but some recent developments in South Africa (“SA”) indicate that this...

On 26 November 2021, the Italian tax authorities (“ITA”) issued the final version of Circular Letter no.15/E (the “Circular”), providing clarification on the new transfer pricing requirements introduced by Measure no. 360494 (“New Measure”) on 23 November 2020. This article...

Many tax jurisdictions encounter difficulties exercising their tax legislation against taxpayers who do not reside in their jurisdictions. The adoption of a simplified registration and collection mechanism is one of the approaches suggested by the OECD to address these difficulties....

Rapid digitalisation and globalisation have led to significant changes in business operations. The digital economy has also uncovered vulnerabilities in the basic rules that have governed global taxation in the past, creating opportunities for profits to be “shifted” to lower-taxed...

The South African (“SA”) tax regime is being strengthened by the implementation of base erosion and profit shifting (“BEPS”) action 4, relating to the limitation of interest deductions, but extra borrowings by businesses to deal with Covid-19 has caused the...

Startups and entrepreneurship are concepts that have recently grown more important globally. To put it simply, startups are entrepreneurial companies that are generally established to offer solutions to any problem and exhibit rapid growth potential. In many countries, the importance...

As of 13 July, 132 of 139 jurisdictions (including Bermuda, Cayman Islands, BVI, Switzerland, and the Bahamas) agreed to the OECD Pillar 1 and 2 proposals as refined by the US initiative.  The seven that did not were: Ireland, Estonia,...

The Asian Development Bank has forecast that developing Asia’s growth is forecast to rebound to 7.3% in 2021 and 5.3% in 2022. This compares to 4.2% and 4.4% respectively for Europe (see here) and 6.9% and 3.6% for the US (see here). Businesses already with a footprint in...

This article identifies the different types of documentation requirements in three macro-areas (i.e., Pan Europe, Asia-Pacific and America) and it explains the thresholds used for the different taxpayers’ obligations. In addition, it provides an overview of the administrative penalties imposed....

Advance pricing agreements (“APAs”) could provide taxpayers and revenue authorities with some certainty during the unprecedented times that we are living in. The African APA landscape is however underdeveloped, but some recent developments in South Africa (“SA”) indicate that this...

While the first reporting deadlines for most EU members expired on 31 January 2021 and respectively 28 February 2021, there are still questions outstanding about whether intermediaries are obliged to report arrangements to tax authorities, or if they can use...

The African continent boasts a beautiful and diverse array of countries offering a wide range of valuable natural and human resources to the world economy. The past decade has seen significant foreign investments in African jurisdictions, ranging from massive investments...

Covid-19 has brought unprecedented social and economic challenges that will durably impact the world economy. Specifically, the pandemic has surrounded the Multinational Enterprises (MNEs) with many issues to be managed such as: insufficient cash flows,unpredictable profitability, unreliable third-party data (which...

Covid-19 has brought unprecedented social and economic challenges that will durably impact the world economy. Specifically, the pandemic has surrounded the Multinational Enterprises (MNEs) with many issues to be managed such as: insufficient cash flows,unpredictable profitability, unreliable third-party data (which...

(Updated 30 March 2021) Recent developments in transfer pricing documentation requirements should prompt MNCs to reassess management of cross border tax compliance. With a focus on protecting tax revenues in straightened economic times, many jurisdictions are focussing on transfer pricing...

While 2020 is a year we may all wish to forget, changes made during the year on Transfer Pricing (TP) give us some clues as to the primary drivers of TP behaviour in 2021. These clues include US guidance from...

Mazars has submitted comments in response to the Organisation for Economic Co-operation and Development’s (“OECD”) public consultation on its proposal for taxation of the digitalized economy, released last October. The proposals The OECD project refers to challenges associated with, and...

In February of this year, the Organisation for Economic Co-operation and Development (OECD) released guidance for multinational enterprises (MNE’s) and tax authorities, on applying the arm's-length standard to controlled financial transactions. The guidance, which the OECD plans to include in the...

The OECD released its guidance on the transfer pricing implications of the Covid-19 pandemic on 18 December 2020. This guidance was eagerly awaited by many MNEs whose statutory accounts will be closed by the end of the year, and which...

Near-term objective of the South African Revenue Service confirmed: “Remaining focused on international taxes, particularly aggressive tax planning using transfer pricing.”  The South African (“SA”) economy, like many others, has been severely impacted by the Covid-19 pandemic. A recent speech...

The Covid-19 pandemic has far-reaching consequences, and will have serious implications on transfer pricing for many multinational enterprises (“MNEs”). This is particularly challenging for businesses to manage due to the current lack of guidance from the OECD.  With this guide,...