The Fiona Show: Hot Off the Press: Recent Episodes
CrossBorder Solutions
Looking for the latest transfer pricing headlines in one quick, easy-to-digest podcast? Look no further! Join Matthew DeMello, host of CrossBorder Solutions' transfer pricing podcast 'The Fiona Show', for a weekly rundown of the latest news and major changes in the global regulatory climate.
What’s the latest on the OECD’s global tax plan? Why is Poland reviewing its transfer pricing legislation? And what is in those new OECD guidelines, anyway? These stories and more on the latest Hot Off the Press podcast.
Which jurisdiction has new transfer pricing reporting standards? Which country has written draft laws? And which jurisdiction isn’t particularly excited about the OECD’s two-pillar plan going into effect? We’ve got it all for you hot off the press.
Omicron concerns mean some industries could see changes to their benchmark rates due to continued workplace disruption, the EU’s new year resolution to prevent shell companies from being used for tax avoidance and evasion is off to a good start, and two major Amazon stakeholders request the company adhere to GRI standards for country-by-country reporting.
Many countries are making regulatory changes, the OECD is preparing to launch a global tax plan, and the U.S. government is busy NOT, for the moment anyway, “building back better.” What do you need to know before the year ends? Tune into today's episode of The Fiona Show: Hot Off the Press to find out.
The Finnish tax authorities are updating transfer pricing rules, the Italian tax authorities are clarifying their regulations, and the ATO is evaluating their efforts to make companies more proactive about tax compliance. (Spoiler alert: It’s working.) These stories and more on the latest The Fiona Show: Hot Off the Press podcast.
What’s Coca-Cola’s latest move to get out of transfer pricing trouble? Why is the Netherlands cracking down on shell companies? And what can you expect from new transfer pricing requirements in the U.K.? These stories and more on the latest
What does Build Back Better mean for taxpayers? How is Poland stepping up its transfer pricing regime? And why are mutual agreement procedures for transfer pricing cases on the rise? These transfer pricing headlines and more on the latest Fiona Show: Hot Off the Press podcast.
Romania puts a finer point on what it means to be a "large company" in their jurisdiction, the EU falls in line behind a new directive supporting adoption of the OECD's proposed global tax plan (even Ireland!), and the European Parliament gives a thumbs-up to public country-by-country reports.
What do developing countries have to say about Pillar One and Pillar Two? Are HMRC’s efforts against tax evasion paying off? And why should every company construct a robust functional analysis? These stories and more on this week's Hot Off the Press podcast.
Bottleneck summer stretches into bottleneck holiday season, and tax professionals collectively watch and wait to see what becomes of the Biden recovery bills.
Fake news, political organizing, and now, transfer pricing – Facebook is never without its fair share of drama. Plus, what’s in Ireland’s Finance Bill 2021 and the OECD gets serious about MAPs.
Which countries are updating transfer pricing legislation? What do certain tax authorities want to see in local files? And are those country-by-country reports complying with BEPS Action 13’s minimum standards? We’ve got the goods right here, hot off the press.
The OECD lands both Pillars One and Two negotiations, 'better late than never' is the motto for transfer pricing documentation in the Dominican Republic, and when it comes to fighting tax avoidance and evasion, the EU Commission doesn’t back down.
What has to happen between now and the G7 meeting at the end of October to move the OECD's global tax deal forward? Why is the pressure on for Ireland to get on board? And what's in the details of Jordan's new transfer pricing requirements?
What surprising documentation strategy should you employ in Asia-Pacific countries? When can you expect public country-by-country reporting in the EU? And why is the Belgian Tax Authority so interested in building a time machine back to 2009? These stories and more on the latest Fiona Show: Hot Off the Press podcast.
How do developing countries feel about the OECD’s global tax reform? What is the latest on EU state aid? And will Ireland sign on for a global minimum tax? These stories and more on the latest Hot Off the Press podcast.
What’s Poland’s latest move to crack down on tax avoidance? Will advanced pricing agreements become a thing of the past for certain Mexican factories? And what’s really going to happen with digital services taxes after Pillar 1 and 2 officially come into play? These stories and more on this week's Fiona Show: Hot Off the Press podcast.
What makes the global tax plan’s new multilateral treaty so complex? Why is Hungary still holding out on a global minimum tax? These stories and more on the latest Fiona Show: Hot Off the Press podcast.
What's happening with Germany’s tax treaties? What will the end of LIBOR mean for transfer pricing in Australia? And where is transfer pricing scrutiny on the rise right now? These stories and more on this week's Hot Off the Press podcast.
Telecom companies are calling for an exclusion from the OECD's Pillar One proposal, it's not the local tax administration's fault you're not sure which supporting documents are acceptable in arm's length pricing in the Ukraine, and new COVID guidance on transfer pricing from Hong Kong's Inland Revenue Department.
On this episode of The Fiona Show: Hot Off the Press, we explore the United Arab Emirates’ mutual agreement procedure guidance, Poland’s Ministry of Finance recommendations for businesses impacted by Covid-19, and how countries compare to their peers in tax-dispute resolution.
On this episode of the Fiona Show: Hot Off the Press, learn about Iceland’s transfer pricing penalties, Russia’s pre-audit analysis focus, and Germany’s new administrative principles.
How is the IRS helping taxpayers navigate stock-based compensation? Which country is tackling transfer pricing adjustments and MAP requests in its latest circular? And why is Oman suspending country-by-country reports? We’ve got the answers on the latest episode of The Fiona Show: Hot Off the Press.
Which country is updating its transfer pricing regulations? How is Denmark seeking to reduce compliance burdens for Danish taxpayers? And what does Madagascar’s latest guidance entail? Find out on this episode of The Fiona Show: Hot Off The Press.
Why have 131 countries signed on to support global tax reform? Which Central European country is trying to streamline its transfer pricing requirements? And how is Spain helping taxpayers with transfer pricing disputes? This week’s episode of The Fiona Show: Hot Off the Press has the answers.
How is the Finnish tax authority navigating legal loss? What’s does progress look like on public tax disclosures in the United States? And what’s on the horizon for Medtronic and the IRS? We’ve got the answers on the latest episode of The Fiona Show: Hot Off the Press.
Israel joins the OECD's framework on taxation of the digital economy, Qatar taxpayers are breathing a sigh of relief, and behind the European Commission's new state aid case against French utility company, Engie.
Kenya isn't wasting any time when it comes to compliance; why Coca-Cola is trying to get back in the legal ring with the IRS; and what a progressive tax means for Argentinian taxpayers.
Inside the G7's global minimum tax announcement, where public country-by-country reporting falls on the EU's itinerary, and Peru releases guidance on multi-year data.
Argentina lends a helping hand to tax payers, the European Commission cracks down on shell companies, and Costa Rica joins the OECD.
Paraguay homes in on commodity transactions, Ukraine imposes new requirements, and the United States latest play in the global minimum tax game.
New transfer pricing rules in the Dominican Republic, intangible transactions aren't quite as sticky in Australia anymore, and the European Commission pushes new fronts in tax transparency.
The United States is ramping up its tax transparency initiatives, inside Amazon's narrow escape in the EU state aid case, and Italy gets taxpayers to swallow its spicy digital service tax.
Spain gives taxpayers a helping hand in its latest guidance, inside the legal loss that melted Tetra Pak, and the UN updates its transfer pricing manual for developing countries.
Canada releases its 2021 budget, Poland irons out a new and improved definition of controlled transactions, and Vietnam's Decree 132 finally kicks in.
Ireland examines its tax treaty policy, Avery Dennison sends the Chilean Tax Authority packing, and Indian taxpayers can breathe a sigh of relief.
A closer look at the new US proposal for Pillar One, 12 tax havens share details of business entity activity with the OECD, and Singapore’s latest guidance tackles centralized activities in MNEs.
The HMRC moves the UK closer to OECD guidance on transfer pricing, the IRS prepares guidance from the fallout of the Altera case, and Poland is tightening the reins on tax havens.
Greece issues COVID 19 restrictions, Bahrain says 'yes' to country-by-country reporting, and Luxembourg cracks down on non-cooperative jurisdictions.
Mongolia gets its first transfer pricing assessment, EU public country-by-country reporting is a "when" not an "if", and a 20-year legal battle over software payments comes to a hard stop.
Argentina and the U.S. are taking their relationship to the next level, the Philippines issues new guidelines on related-party transactions, and Singapore updates their COVID transfer pricing guidance from September 2020.
Zambia introduces country-by-country reporting rules, the days of transfer pricing mismatches are numbered in the Netherlands, and the IRS would like you to not mistake their COVID kindness for post-COVID weakness.
Spain won't let you take a siesta on your transfer pricing, paper filing is so last year (in Thailand, anyway), and Ireland's extended lockdown isn't the only thing making headlines this week.
Change is in the air in Taiwan, transfer pricing scrutiny is heating up faster than a day in Bangkok, and a new submission deadline for Danish taxpayers.
The Dominican Republic releases their annual tax guidance, the war wages on between Coca Cola and the IRS, and Ferragamo can't seem to walk away from its use of the resale price method.
Croatia’s arm’s length interest rate for loans to related parties is decreasing, transfer pricing in the US gets a facelift, and Israel’s new tax circulars clarifies how to treat intercompany recharges from stock-based compensation.
Paraguay's newest guidance broadens the definition of related party transactions, Qatar's tax portal is now online (along with its new set of rules), and Dow Chemical finally comes out victorious against the CRA over intercompany transactions with foreign related parties.
What Tele2Treaury AB's loss in Swedish Tax Court means for transfer pricing, working from home gets easier on taxpayers in new OECD guidance, and Rwanda's new rules target deemed controlled transactions.
Airbnb is on the IRS's naughty list, Malaysia increases penalties for failing to file contemporaneous documentation, and Sweden irons out the wrinkles in DAC6's transfer pricing requirements.
HMRC is opening criminal investigations into companies suspected of profit-diversion, Ghana joins the BEPS Action 13 club, and interest-free foreign subsidiary loans are now a red flag for an audit in Australia.
The United States and Turkey fast-track procedures for sharing country-by-country reports, everything you need to know about Canada's new T1134 form, and what the latest French High Administrative Court ruling about ValueClick means for multinationals.
Germany's new transfer pricing guidance emphasize that cooperation goes a long way, the OECD publishes new details on hard-to-value intangibles, and the debate on public country-by-country reports continues.
The HMRC clamps down on profit diversion, the US and Germany lock-in their competent authority processes, and the CRA is back in the legal ring with Cameco.
Italy revamps its transfer pricing rules, France prepares to enforce its digital services tax, and the OECD issues a new list of countries with ongoing harmful tax practices.
The use of MAPs is up, Blackrock reigns victorious in its legal fight with the HMRC, and Coca Cola waves a white flag in its 5 year brawl with the IRS.
Change is on the horizon in Lithuania, Vietnam throws out their old transfer pricing rules, and Taiwan believes sharing is caring... when it comes to country-by-country reports, that is.
Panama is the 56th country to adopt BEPS Multilateral Instrument, Colombia sets a deadline on registering commodities agreements, and the ATO v Glencore saga comes to an end.
Changes to Zambia's transfer pricing, India will retain its tolerance range, and nothing is ever set in stone at the OECD.
Bruno Le Maire pushes the OECD on global digital tax reforms, value chains somehow stayed intact through COVID, and don't judge Ecco's transfer pricing until you've walked a mile in their shoes.
Where is your greatest risk of transfer pricing audits? Which tax authority is lessening penalties? Happy birthday country-by-country reports? These questions and more answered..
The IRS only has so much sympathy when it comes to APAs in a pandemic, striking the Cayman Islands from the EU's blacklist raises some eyebrows, and the OECD global digital service tax talks suffer a major setback.
A COVID test manufacturer tests positive for tax evasion, another hold-up in COVID transfer pricing guidance from the OECD, and the EU Commission is back for round 2 in the Belgian tax aid case.
The EU Commission goes back to the drawing board on the Apple State Aid, Singapore issues its new COVID related transfer pricing guidance, and what you need to know about Hong Kong's new information request form.
Poland is back in the transfer pricing ring, the EU is inching closer to taking country-by-country reports public, and COVID means "business as usual" is over in New Zealand.
Russia and Hong Kong prove teamwork makes the dream work, Poland makes corporate income tax noise, and Belgium leans into their 'good cop' role.
The Italian Supreme Court thinks recent reforms to the EU’s taxation framework on interest and royalties between parent companies and subsidiaries to actually mean something, a big potential change on the horizon for how software payments are taxed worldwide, and France thinks the U.S. is trying to sabotage global digital tax talks.
Chile mandates transfer pricing documentation, Netflix is now in hot water with South Korea, and just because the CRA takes issue with your business restructuring doesn't mean the Canadian tax courts will.
Brazil tries to crowdsource research on safe harbor rules, Airbnb comes out in favor of a "simple" global digital service tad, and Australia clamps down on thin capitalization with a tried and true method.
Ecuador straightens out transfer pricing on their chief export (bananas), the pros and cons of the profit-split method in COVID, and the bottom line on new ATO guidance on intercompany loans.
God help you if COVID-related wage subsidies are caught moving offshore, India straightens out their MAP, and Vladimir Putin has a new, foreign tax-related enemies list.
The G20 is still committed to resolving Pillar One and Pillar Two proposal issues by end of 2020, what the ATO will do to keep Jobkeeper benefits out of offshore hands, and the rise of digital desk audits in the wake of COVID.
The EU General Court lets Apple off the hook for a 13 billion euro tax bill to Ireland, what country-by-country reports tell tax authorities, and the coronavirus makes life harder for everyone (including transfer pricing practitioners).
The inside scoop on new country-by-country reporting rules from the United Arab Emirates, Germany holds its ground on DAC6 reporting deadlines while the rest of the EU moves to extend by another six months, and it's game on for a tarriff war between France and the U.S. over digital service taxes.
Cameco wins against the CRA again, a friendly reminder not to submit your local file via paper or email to the ATO, and the OECD hints that members will absolutely target profitable MNEs to help close budget deficits when things get back to "normal."
The UK pushes back DAC6 deadlines by six months, and a tale of two jurisdictions (Israel and Denmark) when it comes to burden of proof.
The post-COVID transfer pricing fallout in a single sentence: If tax rates don’t rise, count on more transfer pricing audits.
The OECD wants to know what about transfer pricing in the time of COVID-19 most keeps MNE tax professionals up at night, new regs from Maldives, and a word of advice on intercompany loans and where tax authorities will be looking to make up for coronavirus losses.
Non-EU countries need to share information with the EU on the beneficial ownership of assets or else get labeled as havens, Denmark gets serious about BEPS, and tax authorities try to make transfer pricing reporting easier amid COVID-19.
The need-to-knows on Ukraine's revised tax code, India gets less ambiguous on transfer pricing, and the OECD changes guidelines on CbC reports.
The end game of the Czech Republic's punishing DST, Argentina gets organized, and is the HMRC getting soft? The Tax Justice Network is using the h-word to describe the UK agency.
DAC6 officially gets its deadlines pushed three months, Brazil's new DST throws a wrench into its efforts to align with the OECD, and a closer look at the German Finance Ministry's new changes to transfer pricing rules.
The EU thinks the Netherlands gave IKEA's Dutch subsidiary the tax break equivalent of state aid, the US threatens retaliation of India's "Google Tax", and Colombia and the OECD finally tie the knot.
DAC6 requirements are getting pushed for COVID, the EU says that profit shifting hurts public services in the European COVID response, and South Korea makes transfer pricing easier (and then harder) with more reforms.
The OECD and IRS release coronavirus fallout guidance and India's 2 percent equalisation levy on e-commerce arrives.
Luxembourg tightens up its transfer pricing regime, the IRS just wants you to tell the truth (sigh), and the OECD wants members to hurry up with the dispute resolutions already!
Coronavirus may not stop countries from passing their own DSTs but it is helping MNEs extend their deadlines for handing in documentation. Plus, Norway mans up on BEPS.
Argentina pushes documentation deadlines, Iceland gets icy with taxpayers, and India stabs BEPS in the back.
Serbia just wants everyone to be on the same page ... of its new transfer pricing rulebook, the British Virgin Islands are now accepting country-by-country reports, and Poland implements new information demands on multinationals.
The world asks the Supreme Court to rule on Altera vs. the IRS - and the tech sector asks them to rule in favor of Altera, the OECD's 2020 review of country-by-country reporting arrives, and get brace yourselves for Belgian transfer pricing audits
Tips for handling your transfer pricing in the time of COVID-19, South Africa is onto profit-shifting MNEs, and Facebook's fight with the IRS could change cost-sharing arrangements as we know them.
Belgium kicks its crackdown on base erosion and profit shifting into high-gear, Turkey finally institutes documentation requirements, and the IMF’s Michael Keen tells the International Fiscal Association that the arm's length principle's days may be numbered.
There's a bill to make country-by-country reports public in the House of Representatives, there's a bill to block high-tax exemptions from GILTI in the Senate, and the G20 puts its thumb on the scales in favor of Pillars One and Two.
The EU deems the Caymans a lost cause, Altera and the IRS head to the Supreme Court, and transfer pricing tops Spain's tax agenda this year.
The ATO is coming for intangible assets, the golden arches find themselves in Brazil's crosshairs, and the OECD's digital tax solutions see signs of global support.
PUMA's Swedish subsidiary pays for fumbling their FAR analyses, the OECD Inclusive Framework asks if country-by-country reports go far enough, and are questionable intra-company transactions keeping you up at night?
The Dominican Republic tweaks documentation thresholds and its "white list" of not-tax havens, worldwide cacophony over the future of digital service taxes, and what's a few payments from devalued stock in a foreign company jointly owned between family? Danish Tax Court says: a controlled transaction.
Colombia sets deadlines for documentation, the OECD tells an an international tax conference that the Pillar One and Two trains have left the station, and Royal Dutch Shell bares their 2018 country-by-country report for all the world to see.
The Italian DST goes into effect, Brazil's lagging way behind on MAP requests, but at least you can count on Finland trying to make transfer pricing easier this week.
Warning: a draft for a new German tax law could turn transfer pricing in the country on its head, South Korea (makes it look like they) simplified their refund process, and the OECD walks back requirements that countries share local files to meet Action 13 minimums.
Turkey's DST submits to a higher power, inside the EU VAT system overhaul, and Georgia's decree 366 leans harder on 2017 OECD rules.
The IRS releases final regulations on the BEAT, the latest EU effort to make country-by-country reporting public fails, and a closer look at Colombia's new permanent residence guidance.
Steve Mnuchin pulls the chair out from under the same OECD Pillar One proposals he was advocating for at the last G20 summit, then the bickering begins over Pillar Two, and the IRS asks the Supreme Court to skip hearing SIH's appeal in a $377 million payout for unpaid taxes stemming from a loan guaranteed by its foreign partners.
Ireland doesn't want to count its corporate tax revenue chickens just yet, and the latest in the global digital service tax drama: no one knows what to make of Pillar One reforms and a closer look at Amazon's hot take on the multilateral solution.
BHP pays up $390 million to the ATO, the Ninth Circuit Court rules against Altera, and India is not feeling the OECD's multilateral solution while developing countries cheer their counter offer.
The OECD leaves a very passive-agressive refridgerator note for all of you who can't seem to get your CbC reporting right, how the EU Council annexes shame tax havens into cleaning up their act, and it looks like the list of countries adopting unilateral digital service tax regimes is about to grow.
Don't look to Bulgaria for a relaxed transfer pricing regime anymore, the G24 gives their two cents on a multilateral digital services tax, and tune in to find out if you meet Hong Kong's CbC report threshold.
Koalas, kangaroos, and the ATO's new simplified transfer pricing record keeping standards. Oh my?
The latest on the Philippines' August 29 Memorandum, and more European countries cross the digital services tax Rubicon.
The EU Commission is trying to figure out how much power it actually has, and Qatar joins the CbCR club.
Mexican authorities add enforcing transfer pricing regulations to the country's list of problems, digital taxation is coming your way - this time via Turkey, and a Draft Practical Compliance Guide gives us an inside look at how the ATO thinks.
Are the chances of a transfer pricing audit increasing in Saudi Arabia? You bet they are. Plus, the latest on Panama's CbC reporting framework and the OECD celebrates "Tax Certainty Day".
"Taxation of the Digital Economy" becomes one of our new and least favorite popular phrases, Canada and Switzerland become the latest countries to deposit their tax instruments to the MLI, and Israel's transfer pricing policy isn't as relaxed as you think.
Yes Virginia, CbC reports are gaining on you. Plus: Glencore triumphs over the ATO and a preview of Canada's multilateral instrument.
French President Emmanuel Macron learns the art of keeping himself in the news, pub-loving tax execs in Ireland can soon lift a pint in memory of the country’s relaxed transfer pricing regime, and the early bird doesn't always catch the worm - at least not in Denmark anyway.
What's the correct definition of an intangible asset again? Amazon is scoring on the IRS with their answer. Maybe Chevron got off easy in the ATO's clampdown on intercompany loans. And sorry Apple, but the glory days of Irish tax breaks may be over.
The OECD Inclusive Framework just got stronger, the Multilateral Instrument is making waves with tax payers in Luxembourg, and Danish tax authorities give Just Eat some shade for what they paid in taxes to the UK.
If you were perplexed about Qatar’s CbC reporting requirements, have no fear: we’re about to clear things up, Ecuador’s tax administration is done messing around, and why the UAE isn't just your typical tax haven.
Good news for anyone confused about Hong Kong’s transfer pricing requirements, sometimes the OECD's Inclusive Framework has good news about tax jurisdictions, and tune in to find out what country is actually making transfer pricing easier.
The Inter-American Center for Tax Administrations may be on its way to concensus but the G7 isn't so lucky, the U.S. Senate's backlog of tax treaties it has to approve gets a little shorter (finally), and an update on where Altera's battle with the IRS will go from here.
Brazil’s days as a transfer pricing anomaly may be numbered, India's new budget is great for corporations but not-so-great for high-earning individuals, and a closer look at Egypt's new guidelines.
Thailand's Draft MR sounds an awful lot like the OECD guidelines, the French senate pulls the trigger on the digital services tax, Spanish-based IKEA Distribution Services are victorious in court thanks to their benchmarking, and Gibraltar and Bosnia join the OECD.
The European Commission’s latest round of economic reports, Bulgaria - exhale - finally mandates transfer pricing documentation, and New Zealand gets impatient waiting for the OECD's digital tax recommendation.
A heads up on filing Panama's Form 930, Sweden's new reforms, Belarus clamps down on resident MNE's, and Finland's new female-led government gets serious about raising revenue from transfer pricing.
The CRA isn't quite as powerful as it thinks, Costa Rica's new VAT, and the Czech Republic's ridiculous new take on the digital services tax.
A wakeup call for U.S. multinationals doing business in the U.K., Argentina gets busy, looks like someone finally told Paraguay it's 2019, and Uber fastens their seatbelts.
India and the United States agree to exchange CbC reports, the ATO strikes again, a closer look at the German Ministry of Finance’s updated Application Decree on the General Tax Code, and are you an MNE entity doing direct sales in Italy? Well, you're going to want to tune into this episode.
On today's episode: News from the Seychelles Revenue Commission, don’t blame the Minister of Finance and Economic Development if you submit the wrong transfer pricing documentation in Zimbabwe, and the Swedes are willing to give some fancy looking incentives to ensure companies are filing pristine documentation.
The latest transfer pricing news for the week of May 27th, 2019: Japan releases its 2019 tax plans, Italy's rates take a plunge (woo-hoo!), Hong Kong gets busy, and the United States is not so pleased with France's approach to the long-dreaded digital service tax.