TPcases

On 1 October, 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 ...

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 ...

On 27 March 2024, new paragraphs (3d) and (3e) were added to the German Foreign Tax Act (Außensteuergesetz – AStG) regarding intragroup financing. Paragraph (3d) concerns the determination of arm’s ...

On 19 February 2024, the OECD announced the release of the report on Amount B, which provides a simplified and streamlined approach to the application of the arm’s length principle ...

The Swiss Federal Tax Authorities have published an Article on the status of transfer pricing legislation in Switzerland as of 1 January 2024. The Article describes the existing legal basis ...

On January 19, 2024, the Maltese Commissioner of Taxes and Customs published local guidelines in relation to the transfer pricing rules introduced in Malta in November 2022. The local guidelines ...

17 January 2024 the Australian Taxation Office published the final version of its Practical Compliance Guideline PCG 2024/1 Intangibles migration arrangements. The PCG has previously been released in drafts as ...