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The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.
The OECD has asked transfer pricing officers in multinational enterprises to participate in an online survey on transfer pricing comparability data . . .
The US Senate Finance Committee on April 30 released comment letters submitted to Senate working groups that are currently analyzing US tax reform options. The comments were submitted in . . .
The UK's HM Revenue and Customs, on March 30, released interim guidance on its new diverted profits tax, set to go into effect April 1. The guidance uses practical examples to explain . . .
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
Christian Aid on June 9 called the G7 leaders support for mandatory binding arbitration for multinational tax disputes "deeply troubling," stating that the mechanism could further harm poor countries . . .
Ireland's Tax and Duty Manual has been updated with expanded information regarding the procedures that migrating companies should use to elect to defer their exit charge under the tax laws, Irish Tax and Customs announced on May 26. See, Revenue eBrief No. 53/15.
The US on October 29 released seven international practice units. . .
Thailand's Cabinet on May 7 approved a draft act introducing new transfer pricing provisions, including documentation requirements, writes PwC in a May 18 report. For details, see PwC.
The US IRS on May 6 issued two revenue rulings that conclude that transactions amount to section 351 transactions followed by D reorganizations . . .
UK clothing retailer Next owes additional £22.4m tax after a First-Tier Tribunal ruled the firm’s tax avoidance structure known as a rate-booster was artificial tax avoidance, the UK' s . . .
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) have requested stakeholder input on US tax reform, including international tax reform. The goal is to provide input for five bipartisan Finance Committee working groups that . . .
The UK on May 28 released a tax information and impact note on UK regulations issued March 11 that amend the worldwide debt cap. the regulations prevent changes to accounting standards from disallowing certain financing costs for investment entities. See, Corporation tax: changes to the worldwide debt cap (WWDC) provisions.
The Business Roundtable, an association of US company CEOs, on March 11 released a PWC report it commissioned which concludes that the US's high tax rate coupled with its worldwide system of taxation disadvantages US businesses in the global cross-border mergers and acquisitions market, leading to foreign takeover of US businesses . . .
China's State Administration of Taxation (SAT) on July 22 released an English-language translation of a June 3 announcement describing new policies . . .
ndia's Committee on Direct Taxes on May 26 requested that stakeholders submit written comments on the issue of whether the government should impose minimum alternate tax (MAT) on gains of foreign financial institutions (FFIs) that arose prior to April 1. The committee, headed by Justice A.P. Shah, former. . .
Hong Kong's Treasury Branch on April 24 launched a consultation on the legislative regime and operational framework for implementing automatic exchange . . .
Staff of the OECD, UN, IMF, and World Bank on November 6 released a report Options for Low Incomes Countries’ Effective and Efficient Use of Tax Incentives for Investment. The report was prepared at the request of the G20 Development Working Group. See: Report.
The UK's HMRC on January 30 published a consultation paper entitled "Strengthening Sanctions for Tax Avoidance," setting out proposals to address the serial use of tax avoidance schemes and proposing to introduce additional penalties . . .