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 . . .
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 . . .
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The OECD today released revised draft guidance on the attribution of profits to permanent establishments (PEs) as well as revised draft transfer pricing guidance on profits splits.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 . . .
Tax advisors, accountants, banks, lawyers, and other intermediaries who design and promote potentially aggressive cross-border tax planning schemes and, in some cases, the clients that receive such advice, would be required to meet new reporting. . .
The Council of European Union at a meeting today failed to reach agreement on proposals to reduce the VAT rate for electronic publications and temporarily apply a generalised reverse charge mechanism; the EU VAT e-commerce proposal was also discussed, writes Davide Anghileri of the University of Lausanne . . .
Irish chartered accountant JP Canavan discusses Ireland’s decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .
An official report describing the outcome of the fourteenth session of the UN’s Committee of Experts on International Cooperation in Tax Matters (Committee of Experts) was released on the UN website this week. The fourteenth session . . .
Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
Sriram Govind, a research and teaching associate at the Institute for Austrian and International Tax Law, discusses India’s choices for the multilateral instrument and possible implications to its tax treaty network . . .
The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .
India transfer pricing specialist Ajit Jain discusses the government’s June 7 decision to add a new transfer pricing safe harbor for low-value adding intragroup services and reduce existing safe harbor margins for knowledge process outsourcing services, contract research and development services, and other services.. . . .
Officials representing 68 countries and jurisdictions on June 7 signed a multilateral instrument to amend their existing tax treaties, adding provisions designed to curtail multinational tax avoidance and strengthen tax dispute resolution . . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .