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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.. . .
JP Canavan discusses the EU Court of Justice's highly anticipated decision in the Euro Park Service case, which further defines the limits of EU Member States’ ability to restrict tax deferral benefits on mergers, reorganizations, and similar transactions . . .
Davide Anghileri of the University of Lausanne discusses Italy's new country-by-country reporting requirements for large multinationals . . .
Switzerland's parliament, on March 10, approved a withholding tax exemption for intragroup interest payments, writes Davide Anghileri of the University of Lausanne. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP's destination-based cash flow proposal to partners and partnerships . . . .
Dublin-based tax specialist, JP Canavan, discusses a March 8 ruling of the Court of Justice of the European Union which concludes that dividends paid by a Belgian subsidiary to its parents, both Dutch UCITS, do not qualify for an exemption from Belgian withholding tax under the EU Parent-Subsidiary Directive . . .
Davide Anghileri of the University of Lausanne discusses a March 7 European Court of Justice ruling concluding that the EU VAT directive is valid under EU law even though it excludes electronically-supplied digital books, newspapers, and periodicals from a reduced rate of VAT . . .
German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
Julian Feiner of Dentons, London, discusses the tax proposals in the UK budget, delivered today, which include proposed revisions to interest deductibility, loss relief, and hybrid mismatch rules . . .