Transfer Pricing Links 04/04/2014

Five advance pricing pacts signed with MNCs: Live Mint (R Nair)

“New Delhi: India signed the first batch of five advance pricing agreements (APAs) with multinational companies on Monday, in a move that will reduce transfer pricing litigation and provide certainty to companies with a presence here.

Such agreements, between a taxpayer and the tax department, define a transfer-pricing procedure for a particular set of transactions. Transfer pricing refers to the practice of arm’s length pricing for transactions between group companies to ensure that a fair price—one that would have been charged to an unrelated party—is levied.”


A whistleblower and a cash problem: Caterpillar’s Swiss tax adventures: Quartz (T Fernholz)

“Today, US lawmakers are grilling Caterpillar executives for shifting profits overseas, and the whole thing rests on whether Caterpillar is a redundant part of its own supply chain.

OK, we’ll explain.”


Two Ways To Fix The Corporate Income Tax: Internationalize it Or Kill It: Forbes (H Gleckman)

“In an important new paper, Eric Toder of the Tax Policy Center and Alan Viard of the American Enterprise Institute say that corporate tax reforms now being debated in Congress fall far short of solving the widespread problems with the levy. Rather than merely lowering rates and tinkering with tax rules for U.S.- based multi-national corporations, as President Obama and many members of Congress have proposed, Toder and Viard argue that the corporate system needs what they call “major surgery.””


Major Surgery Needed: A Call for Structural Reform of the US Corporate Income Tax: Tax Policy Center (E Toder and A Viard)


A corporate income tax can play a useful role by preventing shareholders from deferring tax on retained corporate profits. The current U.S. corporate income tax is deeply flawed, however, because it relies on definitions of corporate residence and income sourcing that corporations can easily manipulate, causing economic distortions and erosion of the corporate tax base. Two structural reform options to address these problems are securing international agreement on better ways to allocate the corporate tax base among countries and replacing the corporate income tax with full taxation of American shareholders’ dividends and accrued capital gains on stock in publicly traded companies.”


US provides ‘essential clarity’ on offshore tax compliance: Caribbean360

“WASHINGTON D.C., United States, Thursday April 3, 2014, CMC – The United States Department of the Treasury and the Internal Revenue Service (IRS) have announced that jurisdictions that have reached agreements in substance with the US on the terms of intergovernmental agreements (IGAs) under the Foreign Account Tax Compliance Act (FATCA) can be treated as having agreements in effect until the end of 2014.”


Webcast – Update on BEPS Project: OECD

“Senior members from the OECD’s Centre for Tax Policy and Administration (CTPA) gave the latest update on:

  • Transfer Pricing Documentation and Template for Country-by-Country Reporting
  • Tax Treaty Abuse
  • The Tax Challenges of the Digital Economy
  • Hybrid Mismatch Arrangements
  • Consultation with developing countries”

Watch the recorded webcast here…

Robert Robillard, CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at”

DRTP Consulting Inc. solutions go beyond transfer pricing and international tax solutions. This blog post originally appeared at The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek advice and counsel from DRTP Consulting Inc. as required.

Posted by drtp On 28 May 2014