Featured News

Updated UN manual reveals India’s transfer pricing positions

January 23, 2017

Bhavik Timbadia and Hussain Sunel of BMR & Associates LLP discuss the newly revised draft UN Practical Manual on Transfer Pricing for Developing Countries, focusing on the India chapter, which reveals Indian tax authorities' current transfer pricing positions, including some surprising views on low value adding intra-group services . . .

France’s diverted profits tax ruled unconstitutional

January 4, 2017

France’s Constitutional Council on December 29 struck down France’s controversial diverted profits tax law, finding it unconstitutional, and also determined that changes to the financial transaction tax are constitutional, writes Davide Anghileri of the University of Lausanne, a contributing editor at MNE Tax  . . .

Apple may lose EU State aid dispute, tax experts say

December 20, 2016

The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company's subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .

Japan’s CFC tax reform: new wine into old bottles?

December 15, 2016

Masao Yoshimura, Associate Professor of Tax Law at the Graduate School of International Corporate Strategy, Hitotsubashi University, Tokyo, writes about a proposal to revise Japan's controlled foreign company law, released December 8 by Japan's ruling coalition . . .

India-Cyprus tax treaty renegotiated: key provisions

December 12, 2016

Mansi Seth, head of Nishith Desai Associates’ US practice, and Ashish Sodhani, a senior member of the firm's international tax practice, discuss the renegotiated India-Cyprus tax treaty, which provides for source-based taxation of capital gains arising from alienation of shares . . .

EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls

December 9, 2016

EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
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