transfer pricing

On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here).  The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA)…

When UK voters went to the polls on 23 June 2016 and voted by a slim majority to leave the European Union, few of them had in mind the impact on taxation.  Future generations are unlikely to view it…

In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search …

Treasury recently released its 2015 Transfer Pricing Advance Pricing Agreements Report to Congress, the seventeenth report since the initial 1999 report.  Each year, the Treasury APA Report describes…

Starbucks Manufacturing BV (SMBV), based in the Netherlands, is the only coffee roasting company in the Starbucks group in Europe. It sells and distributes roasted coffee and coffee-related products …

As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…

In the last few months I have been deeply committed with the Klaus Vogel Lecture, which will be held in September 25, 2015, in the Vienna University of Economics and Business (see invitation here). I…

This post answers the emails received requesting further information on the US Competent Authority, including statistics, based upon my Kluwer Tax Blog post of 25 August IRS Issues New Competent…

On August 12, 2015 the IRS released two final revenue procedures impacting the U.S. transfer pricing regime.  Revenue Procedure 2015-40 concerns the protocols and procedures for requesting assistance…