Davide Anghileri of the University of Lausanne discusses an Italian law adopted April 24 that modifies Italy's transfer pricing provisions to make them in-line with the OECD’s arm’s length principle, adds corresponding adjustments to Italian tax law, and updates the list of intellectual property that can qualify for the patent box regime . . .
President Trump on Wednesday unveiled his tax plan, proposing steep reductions in both individual and corporate income tax rates as well as a move to a territorial tax . . .
International tax lawyer Ashish Goel discusses the Formula One case, an important Supreme Court decision, released Monday, which addresses in detail when a permanent establishment is created in India . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses a Trump administration executive order, issued last Friday, mandating the review of tax regulations, noting that those hoping the order will lead to the repeal of US earnings stripping and/or inversion tax regulations may wind up disappointed . . . .
Australia’s Full Federal Court today dismissed Chevron's appeal in a transfer pricing case involving intercompany loans, handing the Australian Taxation Office (ATO) a key victory. By unanimous judgment, the full bench . . .
Yoshio Uehara, César De la Parra, and Ignacio Mosquera of Chevez, Ruiz, Zamarripa, analyze final rules, issued by the Mexican tax authorities April 3, that implement the transfer pricing documentation and country-by-country reporting scheme set out in Action 13 of the OECD/G20 base erosion and profit shifting (BEPS) plan agreements . . .
The European Court of Justice (ECJ) has ruled that a criminal proceeding can be brought against the legal representative of a company even if the company has already paid a tax penalty with respect to the same act or omission, writes Davide Anghileri of the University of Lausanne . . .
Enhancing EU tax certainty for multinational groups has become a hot topic. The subject was taken up during a recent informal meeting of the Economic and Financial Affairs Council (ECOFIN) in Malta and is also the focus of a new European Commission taxation paper . . .
Cyprus will sign the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting( MLI), Cyprus's Ministry of Finance has announced . . .
US transfer pricing lawyers Robert Feinschreiber & Margaret Kent examine a guidance note, released last week by the UN’s Committee of Experts on International Cooperation in Tax Matters, which concerns transfer pricing issues associated with extractive industries, specifically mining and mineral extraction and oil and natural gas production . . .
The UN's Committee of Experts on International Cooperation in Tax Matters (UN Committee), during meetings held last week, released its revised and updated 2017 United Nations Practical Manual on Transfer Pricing for Developing . . .
The OECD has issued new tax guidance on the common reporting standard, including the CRS XML schema, writes Davide Anghileri of the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses OECD tax guidance, released April 6, which further clarifies the country-by-country reporting rules for large multinational groups . . .
The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . .
Tax professional Ninja-Antonia Reggelin discusses a German parliamentary hearing, held Wednesday, where tax experts provided their views on a controversial proposal to deny tax deductions for some royalty payments made by multinationals to related companies. . .
Tax officials, during a March 28 webcast, discussed the OECD's international tax agenda, including plans to release tax and transfer pricing guidance and promote . . .
The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Davide Anghileri of the University of Lausanne discusses tax guidance issued by the Italian Revenue Agency clarifying Italy's patent box regime, the tax credit for research and development (R&D) activities, and the tax credit for new business assets. . . .
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .