Transfer Pricing Times - First Quarter 2021

In “Answers to Practical Questions About the Pillar One Blueprint”, we review the main elements of the OECD’s Pillar One Blueprint and how multinational companies can assess its potential impact on tax liabilities and double taxation. 

In “Expansion of India’s Equalisation Levy to Impact More Tech Companies”, we discuss the recent expansion of the Indian Tax Authority’s Equalisation Levy that was implemented to address tax issues created by the digital economy.

In “New Regulations on Transfer Pricing Documentation and Penalty Protection Regime in Italy”, we outline the key changes for companies to consider from the provision by the Italian Revenue Agency which amended the 2010 transfer pricing documentation requirements.

In “Canada’s Supreme Court Declines to Hear Cameco Case Appeal; Recharacterization Attempt Fails”, we examine the Crown’s losses in the Cameco and AgraCity court cases that tested Canada’s transfer pricing recharacterization rules.

Finally, in “President Biden and Senate Democrats Propose Revisions to U.S. Tax Code”, we provide an overview of recent proposals for reforming U.S. tax regulations.

We hope that you will find this and future issues of Kroll, quarterly transfer pricing newsletter informative.