An EU Commission proposal to require public country-by-country reporting by multinationals operating in Europe should be extended to cover many more multinationals and to mandate much more robust . . .
Corporate tax reform III was rejected by popular referendum today, with 59.1 percent of the population voting against the Swiss government proposal, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne . . .
Julian Feiner of Dentons, London, discusses proposed Australian legislation, introduced into Parliament February 9, that would implement a diverted profits tax, comparing the draft to the UK DPT . . .
The European Council on February 7 released the Maltese Presidency’s work plan regarding tax measures to prevent base erosion and profit shifting by multinationals, notes Davide Anghileri of the University of Lausanne . . .
Daniel Garabedian and Steven Peeters, of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss a Belgian law passed last week that modifies the tax incentives for multinational enterprises that derive income from intellectual property rights . . .
Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, discusses Ireland's arguments in the Apple State aid case before the Court of Justice of the European Union, as revealed in the government’s summary of legal proceedings, released today . . . .
Davide Anghileri of the University of Lausanne discusses Switzerland's decision to launch a consultation on automatic exchange of information with 20 more countries . . .
Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, Galway, provides an update of the EU Commission's State aid challenge to tax rulings granted by Ireland to Apple . . .
International tax specialist, Ashish Goel, analyzes key tax proposals in India’s 2017-18 budget, released today, that affect cross-border business, including important new interest deductibility limits, rules providing for secondary transfer pricing adjustments, and provisions clarifying taxation of indirect transfers of assets . . .
The US IRS has announced that it has selected 13 tax and transfer pricing topics that it will focus on in an issue-based campaign to increase the tax compliance of large and/or international businesses. In a January 31 announcement, the IRS' Large Business and International division (LB&I) said it will . . .
Davide Anghileri of the University of Lausanne writes about Australian Taxation Office guidance published January 27 designed to help foreign multinationals and other taxpayers understand the ATO's views on what better tax corporate governance practices look like so companies can develop or improve their own tax governance and internal control framework . . .
The German cabinet has approved a draft law limiting tax deductions for cross-border royalty payments to related parties, writes Berlin-based practitioner, Ninja-Antonia Reggelin . . .
Sriram Govind of the Institute for Austrian and International Tax Law discusses a circular issued by the Indian government January 27 which contains welcome clarifications on India's coming GAAR but also includes statements that will likely increase confusion, such as how the GAAR will be applied in some cases involving tax treaties . . .
Julian Feiner of Dentons, London, discusses draft UK proposals, released yesterday, that would change the taxation of carried-forward losses and interest deductions . . .
The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN, and World Bank Group – on January 24 released a draft toolkit addressing ways that emerging economies can overcome lack of transfer pricing comparable data . . .
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 . . .
The ECJ Advocate General in a January 19 opinion concluded that France’s use of GAAR to deny a withholding tax exemption for dividends distributed by a French company to its Luxembourg parent is incompatible with EU law, writes MNE Tax contributing editor, Davide Anghileri of the University of Lausanne . . .
Davide Anghileri of the University of Lausanne discusses Italy's January 17 release of its first investment ruling, which clarifies when a logistics hub located in Italy is a permanent establishment and covers the VAT treatment of goods flowing through such hubs . . .
Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO's approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .
Sriram Govind of the Institute for Austrian and International Tax Law discusses reports that India will not renegotiate its tax treaty with the Netherlands, as it did with Mauritius, Cyprus, and Singapore, and addresses the impact of the countries' expected signing of the BEPS multilateral instrument . . .
EU law requires that a company be given the opportunity to challenge a tax information order issued to implement a tax exchange of information request on the grounds that the request lacks "forseeable relevance," Advocate . . .
International tax specialist Ashish Goel analyzes the major changes made by a new protocol to the India and Singapore tax treaty, signed in late December . . .
The OECD has today released for public comment three draft examples addressing the application of the OECD/G20 base erosion profit shifting (BEPS) Action 6 principal purpose test to . . .