The US is concerned that some countries aim to increase their share of tax revenue from multinational firms by incorrectly applying OECD transfer pricing guidelines on the allocation of risk, a Treasury . . .
A new "toolkit" which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm's length approach can work for all nations but is also an imperfect, "not scientifically pure," document, a UN official said July 18. Michael Lennard . . .
Brazilian attorneys, Francisco Lisboa Moreira and Carolina Silveira Becman of Castro, Barros, Sobral, Gomes, discuuss a Brazilian Federal Revenue Service's opinion on the taxation of amounts paid, credited, used, delivered, or remitted abroad on the acquisition of access and remote use of software as a service (SaaS) . . .
Additional guidance on the implementation of country-by-country reporting by large multinational groups was released today by a countries known as the "Inclusive Framework on BEPS," the OECD has announced. This guidance is designed for both . . .
Monte Jackel follows up on his earlier article on the US Tax Court's decision in Grecian Magnesite discussing the collateral effects the ruling could have on the international tax rules for partnerships . . .
Mumbai attorney and transfer pricing specialist, Ajit Jain, discusses the OECD’s new transfer pricing approach to business restructuring, as described in Chapter IX of 2017 OECD transfer pricing guidelines, released July 10 . . .
Monte A. Jackel, Senior Counsel at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court's July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .
The UK government today announced it will reintroduce its finance bill, including legislation aimed at restricting the amount of interest and other financing amounts that a company may deduct for corporation tax purposes, “as soon as possible” after summer recess, after the . . .
Governments must work together on a regional basis to fight the harmful effects of tax competition and address multinational tax avoidance through devices such indirect transfers of assets, IMF Deputy Managing Director Mitsuhiro Furusawa said . . .
The EU Council will work on the priorities of the new Estonian presidency concerning taxation, particularly modernizing VAT to address the digital economy, ministers announced following an economic and financial affairs (ECOFIN) meeting . . .
The OECD today released a key update to its transfer pricing guidelines for multinationals. The 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration incorporates new transfer pricing approaches agreed to by OECD and G20 countries in the 2015 base . . .
US Treasury has identified eight tax regulations -- including the section 385 debt-equity regulations, the section 367 regulations affecting foreign goodwill and going concern value, and the section 987 foreign currency regulations -- as qualifying for revision under President Trump's executive order mandating a reduction in . . .
G20 leaders affirmed their commitment to international cooperation in the area of tax policy, in a communique released after their July 7--8 summit in Hamburg, Germany."We can achieve more together than by acting alone," the leaders . . .
Today, the EU Parliament approved a proposal for a directive of the European Parliament and of the Council amending Directive 2013/34/EU as regards the disclosure of income tax information by certain undertakings and branches, writes Davide Anghileri of the University of Lausanne . . .
Professor Rifat Azam, Radzyner School of Law, Herzliya discusses the Israeli District Court's decision in Getko Ltd vs. Kfar Saba Assessing Officer, which strives to develop transfer pricing principles and guidelines in the Israeli tax law context . . .
Malta, as holder of the EU Presidency, has offered a compromise proposal to the EU Council that would require large multinational enterprises to publicly disclose tax information on a country-by-country basis, writes Davide Anghileri of the University of Lausanne . . .
The OECD expects to soon release an important update to its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, tax officials said during a June 26 webinar. Officials also discussed the OECD's coming release of a discussion draft . . .
The OECD today released revised draft guidance on the attribution of profits to permanent establishments (PEs) as well as revised draft transfer pricing guidance on profits splits. Both discussion drafts replace earlier drafts . . .