Colombia: CUP method valid for commodity transactions without quoted prices
The Colombian Tax Authority (DIAN) released Ruling 1118 (Int. 81) of 13 February 2024, which provides clarification of the application of the Comparable Uncontrolled Price (CUP) method for commodity transactions between related parties that do not
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OECD: Secretary General’s Tax Report to G20 Finance Ministers
On 19 February 2024 the OECD published the Secretary General’s tax report to the G20 Finance Ministers and Central Bank Governors for their meeting of February 2024. The report covered important international tax developments since their previous
See MoreOECD: Comments Received on Proposed Guidance on Pricing of Lithium
On 26 February 2024 the OECD published the responses received on the proposed guidance to support developing countries in addressing risks of base erosion and profit shifting in pricing lithium. Comments were received from eleven government and
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 25 January 2024 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2022/23 tax year. The transfer pricing work is an important part of
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US: IRS evaluating group membership to fix arm’s length interest rate
On 29 December 2023, the Office of Chief Counsel Memorandum announced that the IRS is considering group membership to determine the arm's length interest rate chargeable for intragroup loans and make a section 482 adjustment. The memorandum provides
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Russia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
See MoreOECD: 2022 Peer Review Reports on the Exchange of Information on Tax Rulings
On 13 December 2023 the OECD released the 2022 Peer Review Reports on the Exchange of Information on Tax Rulings. The latest annual peer review reports cover 131 Inclusive Framework member jurisdictions and jurisdictions of relevance. The BEPS
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UN Adopts Resolution to Set Up a Framework Convention on Tax
On 22 November 2023 the UN general assembly adopted a resolution to commence the process of setting up a framework convention on tax. The framework convention could ensure that the UN is the main body for decision-making on international tax
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Germany: Bundestag approves draft business tax reform bill
On 17 November 2023, the German lower house parliament (Bundestag) passed a bill that seeks to promote economic expansion, stimulate investment, and make the tax system more user-friendly and equitable. Some of the key provisions of the bill
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OECD: Consultation on Transfer Pricing Issues Relating to Lithium
On 6 November 2023 the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) released for public consultation a draft toolkit with the title Determining the Price of Minerals: Application to Lithium. The
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OECD: Guidance on Transfer Pricing Issues for Bauxite
Following the completion of a previous consultation, on 6 November 2023 the OECD published a toolkit with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This toolkit follows on from the publication
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OECD: Practice Note on Transfer Pricing for Minerals
On 6 November 2023 the OECD published the final version of a practice note with the title Determining the price of minerals: A Transfer Pricing Framework. The practice note has been developed after consultation with interested parties with the aim
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UN Tax Committee considers transfer pricing and treaty issues
The 27th session of the UN Committee of Experts on International Cooperation in Tax Matters took place from 17 to 20 October 2023. Subcommittees dealing with various areas of taxation presented updates to the Tax Committee on their
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OECD: Report to the Meeting of G20 Finance Ministers and Central Bank Governors
The OECD Secretary General’s report to the meeting of G20 Finance Ministers and Central Bank Governors covered the following issues: Two-Pillar International Tax Package The Inclusive Framework has now released the text of the Multilateral
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OECD: Multilateral Convention in Relation to Amount A of Pillar One
On 11 October 2023 the OECD’s Inclusive Framework released the finalised text of a multilateral convention in relation to Amount A of Pillar One, to co-ordinate the implementation of the reallocation of taxing rights to market jurisdictions,
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OECD: Sixth Annual Peer Review Report on BEPS Action 13
On 25 September 2023 the sixth annual peer review report was issued under BEPS Action 13, looking at the implementation of the minimum standard on country by country (CbC) reporting by jurisdictions at April 2023. The report covers 136 member
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OECD: Responses to Consultation on Amount B of Pillar One
On 20 September 2023 the OECD published the responses to the consultation on Amount B of Pillar One of the two-pillar approach to taxation of the digital economy. Amount B applies to baseline marketing and distribution activities, simplifying the
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OECD: Report to the G20 leaders meeting of September 2023
The tax report by the OECD Secretary General to the meeting of G20 leaders on 9 to 10 September 2023 outlines the latest international tax developments in international tax reform, including the work on the two-pillar international tax plan;
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