More News–MNE Tax

Europe

EU directive on tax dispute resolution enters into force

July 1, 2019

New rules aimed at resolving cross-border tax disputes . . .

Europe

Guernsey proposes amendments to economic substance, tax residency rules

June 20, 2019

The Guernsey Revenue Service on June 17 announced proposed changes to the economic substance regulations for tax residency. The . . .

Asia-Pacific

Singapore tax guide addresses transfer pricing for commodity marketing, trading

May 28, 2019

Singapore’s Inland Revenue Service on May 24 released a new E-Tax guide aimed at helping . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

IRS issues final partnership regs on allocation of creditable foreign taxes

July 25, 2019

The US IRS on July 24 published final regulations . . .

American Samoa

Dominica removed from the EU tax blacklist

June 17, 2019

The Council of the EU on June 14 removed Dominica from the . . .

Americas

US IRS publishes final section 956 regs applicable to US corporate shareholders

May 23, 2019

The US IRS today published final regulations that provide a mechanism to exclude corporations . . .

Europe

Multilateral tax treaty to enter into force for Norway

July 29, 2019

The OECD today announced that Norway has deposited its instrument . . .

Asia-Pacific

Australian taxation office explains hybrid mismatches through structured arrangements

July 25, 2019

The Australian Taxation Office (ATO) on July 25 issued new guidance on the meaning of . . .

Europe

EU Commission’s publishes decision to probe whether Netherlands tax rulings granted State aid to Nike

July 5, 2019

The EU Commission this week released. . .

Asia-Pacific

India ratifies multilateral tax convention

June 13, 2019

Prabhakar KS of Shree Tax Chambers, Bengaluru, India, discusses the June 12 ratification by India of the Multilateral Convention to implement the Tax Treaty related measures to prevent Base Erosion and Profit Shifting (MLI) almost 2 years after signing it . . .

Asia-Pacific

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

August 9, 2019

The Australian government on August 9 published the synthesized texts of . . .

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UN publishes tax treaty negotiation manual

July 7, 2019

The UN has published a new version of . . .

Americas

US IRS releases proposed PFIC regs, withdraws 2015 regs on insurance exception

July 10, 2019

The US IRS today released proposed regulations under sections . . .

Americas

Japan, Argentina sign tax treaty

June 30, 2019

Japan’s Ministry of Finance on June 27 announced . . .

Europe

Switzerland and Netherlands sign protocol amending tax treaty

June 12, 2019

Switzerland and the Netherlands have signed a protocol of amending their tax treaty . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Asia-Pacific

Switzerland, Iran sign protocol amending tax treaty

June 3, 2019

The governments of Switzerland and Iran have signed protocol amending their . . .

Asia-Pacific

India-Marshall Islands tax information exchange agreement enters into effect

May 26, 2019

Prabhakar K S, Proprietor of Shree Tax Chambers, Bengaluru, Karnataka, India writes that on May 21 India announced that a tax information exchange agreement between India and the Marshall Islands entered into effect . . .

Bosnia and Herzegovina

Bosnia and Herzegovina joins the Inclusive Framework on BEPS

July 11, 2019

The OECD on July 10 announced that Bosnia and Herzegovina has joined the “Inclusive Framework on BEPS” . . .

Americas

US IRS corrects section 987 foreign currency regs

July 1, 2019

The US IRS today made corrections to final . . .

Asia-Pacific

Singapore’s tax treaties with Finland and Guernsey amended by MLI

June 3, 2019

The Inland Revenue Authority of Singapore (IRAS) has announced that amendments to . . .

Albania

Albania signs BEPS MLI

May 28, 2019

Albania on May 28 signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, becoming . . .

Albania

Albania joins Inclusive Framework on BEPS to address multinational tax issues

August 8, 2019

The OECD today announced that Albania . . .

Europe

Germany must recognize other EU States’ profit and loss transfer agreements for tax consolidation, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a letter of formal notice to Germany for refusing to recognize profit and loss . . .

Europe

Ireland updates CFC tax guidance

July 22, 2019

Ireland today updated its Tax and Duty Manual . . .

Asia-Pacific

India deposits MLI ratification instrument with OECD

June 26, 2019

India deposited with the OECD documents ratifying the Multilateral Convention to Implement . . .

Asia-Pacific

Sri Lanka, Denmark to revise tax treaty: Economynext→

June 6, 2019

Americas

US IRS large business unit to identify audit targets using data analytics

May 16, 2019

The US IRS today announced that its Large Business & International (LB&I) division will begin making . . .

Asia-Pacific

Australia considers requiring more taxpayers to file reportable tax position schedule

July 11, 2019

The Australian Taxation Office on July 8 launched a consultation on . . .

Americas

US IRS notes updates to country-by-country reporting instructions

July 10, 2019

The US IRS today notified taxpayers that that updated . . .

Belgium

Belgium deposits MLI ratification instrument with OECD

June 27, 2019

Belgium has deposited with the OECD its instrument ratifying . . .

Americas

Canada ratifies BEPS MLI to fight tax avoidance by multinationals

June 24, 2019

Canada has ratified a multilateral tax treaty developed by more than 100 countries that is designed . . .

More News

OECD announces improvement to MLI matching database

June 18, 2019

The OECD today announced that it has expanded the functionality of a database it provides on its website that is . . .

Americas

US IRS large business unit withdraws cost sharing arrangement directive

June 12, 2019

The US IRS’s Large Business and International Division in a notice published June 4, but dated and effective May 21, has announced . . .

Asia-Pacific

MLI to enter into force for United Arab Emirates

June 6, 2019

The United Arab Emirates deposited its instrument of . . .

Africa

Singapore, Korea sign tax updated treaty lowering withholding tax rates

May 13, 2019

The governments of Singapore and South Korea today signed . . .

Belgium

Denmark must adopt EU controlled foreign company tax rules, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . .

Europe

Gibraltar joins “Inclusive Framework on BEPS” working on multinational group tax issues

July 7, 2019

Gibraltar has joined a coalition of countries working on international tax and transfer pricing issues. . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin