Transfer Pricing Times – December 2019


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In this edition of Transfer Pricing Times, we present the latest and most relevant transfer pricing issues and developments from around the globe.

In the “Highlights from the Public Consultation on the Unified Approach” article, we review the discussions that took place during the OECD’s public consultation meeting in Paris, France on November 21-22, 2019. 

In the “Consultation and Debate Continues on Global Anti-Base Erosion Proposal Under Pillar Two” article, we discuss the Global Anti-Base Erosion Proposal under Pillar Two that seeks to develop rules that would limit multinational’s ability to reduce tax through establishment of a global minimum tax regime.

In the “U.S. Treasury and IRS Finalize BEAT Regulations” article, we summarize the transfer pricing aspects of the final regulations and additional proposed regulations made by the IRS and Treasury on the Base Erosion and Anti-Abuse Tax under Section 59A on December 2, 2019.

In the “Taiwan Releases New Rulings for Transfer Pricing Adjustments and Exemptions” article, we review two recent transfer pricing tax rulings released by the Ministry of Finance in relation to one-time transfer pricing adjustments and exemption thresholds for filing the Master File and Country-by-Country report in Taiwan.

Finally, in the “Updated Related Party Disclosure Forms in Thailand and Malaysia” article, we discuss the recently released new or updated related party disclosure forms in Thailand and Malaysia to support more stringent transfer pricing compliance. 

We hope that you will find this and future issues of Duff & Phelps’ monthly transfer pricing newsletter informative and reliable.