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The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .
US President Trump today released his first budget, presenting tax proposals that echo the principles that the Administration . . .
International tax attorney Ninja-Antonia Reggelin discusses German guidance issued May 17 detailing the limited tax liability and source taxation of cross-border transfers of software and databases . . .
The European Court of Justice in May 17 decision ruled that France's additional tax on dividends is not compatible with article 4 of the parent-subsidiary directive, writes Davide Anghileri of the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses a May 17 European Court of Justice decision finding that Belgium's fairness tax system is incomparable with EU freedom of establishment concepts and the parent-subsidiary directive . . .
Mansi Seth and Afaan Arshad of Nishith Desai Associates discuss today's announcement that the Indian Union Cabinet has approved India’s signing of the multilateral instrument (MLI) to implement the tax treaty measures in the OECD/G20 base erosion profit shifting (BEPS) action plan . . .
The Australian Taxation Office on May 16 issued draft guidelines on cross-border related party financing arrangements. In the . . .
EU states must allow a court challenge to the legality of an information order issued to implement a tax-related exchange of information request on the grounds that the request lacks “foreseeable relevance,” the Court of Justice. . .
A German court has struck down portions of a controversial law that denies tax loss carryforwards following a change of shareholders, ruling that the provisions are unconstitutional, writes international tax practitioner Ninja-Antonia Reggelin . . .
G7 finance ministers and central bank governors, following their May 12--13 meeting in Bari, Italy, said they may be able to back policy measures designed to ensure that tax challenges associated with the digitalization of . . .
Francisco Lisboa Moreira, an attorney with Castro, Barros, Sobral, Gomes, discusses Brazil's country-by-country reporting requirement for large multinationals, identifying unresolved questions associated with the new rules . . .
Nick Drizen of BDO Australia discusses the Australian Full Federal Court's landmark decision in Chevron, providing insight into transfer pricing for intercompany loans . . .
US international transfer pricing attorneys Robert Feinschreiber and Margaret Kent discuss guidance developed during the OECD/G20 base erosion profit shifting (BEPS) project which applies transfer pricing concepts to contracts. . .
The OECD today released an updated list of automatic exchange relationships established between tax authorities to implement country-by-country reporting under Action 13 of the OECD/G20 base erosion profit shifting (BEPS) plan. The OECD also announced activation of automatic . . .
Indian tax officials signed a record number of advance pricing agreements (APAs) in fiscal year 2016--17; nonetheless, India's backlog of unresolved APA cases increased during the . . .
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 . . .