Transfer Pricing Links 04/07/2014

YLE: Court’s transfer pricing decision could cost taxman hundreds of millions of euros

“Finland’s Tax Administration has lost a landmark court case on transfer pricing. The Supreme Administrative Court’s ruling means the taxman could now lose out on hundreds of millions of euros in tax.”


OECD: Gabon joins international efforts to end tax avoidance and evasion

“03/07/2014 – At a ceremony today at the OECD, Gabon signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Gabon is the seventh African country to sign the Convention since it was opened for signature to all countries in June 2011.

With 66 signatories, the Multilateral Convention is the most powerful international instrument available to fight international tax avoidance and evasion”


OECD: Cameroon signs the Convention on Mutual Administrative Assistance in Tax Matters

26/06/2014 – Cameroon has become the 65th signatory of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the most powerful international instrument to fight international tax avoidance and evasion.

To enter into force, the Convention must now be ratified by Cameroon.


IRS Deputy Commissioner (International) Danilack to Resign: Bloomberg BNA (International Tax Blog)

“Michael Danilack, who has served the Internal Revenue Services in two key international positions, confirmed June 25 that he plans to resign July 2. Dolores W. Gregory’s story, which appeared in the June 26 issue of Transfer Pricing Report, follows.

U.S. Competent Authority Michael Danilack has resigned effective July 2.”


Joe Hockey moves on global tax dodgers: The Sydney Morning Herald (M Kenny)

“The federal government is moving to recoup billions by closing loopholes that are exploited by multinational companies to shift profits and losses across international borders to minimise their tax bills.

The moves comes after Fairfax Media reported that Australia’s largest coalminer, Glencore (formerly Xstrata) paid almost no tax over the past three years, despite generating income of $15 billion.”


Ireland Not To Blame For Low MNE Tax Burden: ITI Tax-News (L Charalambous)

“Discussing the effective rate of corporate tax paid by multinationals in Ireland, Cora O’Brien, Policy Director at the Irish Tax Institute, said that Ireland cannot be expected to tax a multinational enterprise (MNE) on its global profits just because it is incorporated in Ireland. O’Brien made the comments while addressing the Houses of the Oireachtas’s joint sub-committee on global taxation, which met on June 17 to assess how best to calculate the effective rate of corporate tax on companies in Ireland. O’Brien said that the debate on Ireland’s effective corporate tax rate ties into international debate on international tax rules being led by the Organisation for Economic Cooperation and Development in its base erosion and profit shifting work.”


Comptroller and Auditor General preparing to examine transfer pricing cases: The Economic Times (G S Patil)

“NEW DELHI: The Comptroller and Auditor General (CAG) is preparing to examine transfer pricing cases, which have significant revenue implication for the exchequer and lead to longdrawn litigation between companies and tax authorities.

The CAG has so far not been auditing transfer pricing cases, mainly because of the shortage of staff with expertise in international tax rules.”


FATCA tax deal forces Canadian banks to send info to IRS: (J Fitz-Morris)

“When Canada’s banks reopen for business on July 2, they will begin formally operating as informants for the United States Internal Revenue Service — the IRS.

Financial institutions in Canada will be required to ask all new and existing clients opening a new account questions such as where they were born, and possibly where their parents were born.”


Nota Bene: The FATCA hammer blow: Financial Post


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 4 July 2014