TPcases

The Australian Taxation Office’s draft Practical Compliance Guideline PCG 2025/D2 explains how the ATO assesses the tax risk of inbound cross-border related-party financing arrangements and the factors it takes into ...

On 23 May 2025, the OECD issued guidance on common errors made by multinational enterprise (MNE) groups when preparing their country-by-country (CbC) reports. These reports contain valuable information on the ...

Germany has issued guidance on a recent addition to German taxpayers’ transfer pricing documentation obligations. The transaction matrix now required under Section 90 (3) sentence 2 no. 1 AO is ...

12 December 2024, the German Federal Ministry of Finance published updated administrative principles on transfer pricing 2024 (VWG VP 2024). The updates mainly concern the chapter on financial transactions, where ...

1 October 2024, the New Zealand Inland Revenue published a new 2024 edition of its Multinational Enterprises Compliance Focus. According to the publication (page 23), the provision of risk indicators ...

9 September 2024, the Peruvian tax authority – SUNAT – issued guidance on the qualification of services, transfer pricing methods for services and the application of the “benefit test”. Click ...

30 August 2024 the Inland Revenue of New Zealand issued Commissioner’s Statement CS 24/02. The Statement that sets out the Commissioner’s position in relation to the withholding tax obligations that may ...

The Australian Tax Office (ATO) has applied for special leave to appeal to the High Court of Australia against the Full Federal Court’s decision in PepsiCo, Inc. v Commissioner of ...

On 17 June 2024, additional guidance and lists of qualifying and coverred jurisdictions under Amount B was released by the OECD. The additional guidance includes: The definitions of qualifying jurisdictions within ...