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In an effort to provide their tax administrations with tools to combat corporate tax avoidance through transfer pricing, officials from 7 more countries have signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large . . .
The US Internal Revenue Service has today published final and temporary (TD 9815) and proposed (REG-135122-16) tax regulations providing guidance to nonresident alien individuals and foreign corporations that hold financial products providing for payments. . .
The US IRS on January 19 issued temporary (TD 9811) and proposed (REG-127203-15) regulations that require US persons to recognize gain on the transfer of appreciated property in exchange for an interest in partnership which has foreign partners . . .
The US IRS on January 19 issued guidance providing a procedure for the ultimate parent entity of a US MNE group to voluntarily file Form 8975 for early reporting periods. The filing is required effectuate . . .
The US IRS on January 20 released an updated withholding foreign partnership agreement (WP agreement) and withholding foreign trust agreement (WT agreement). The agreements, in . . .
India's finance ministry on January 17 announced that it will suspend the operation of a circular issued last month concerning the taxation in India of indirect transfers of Indian assets through offshore . . .
The US IRS has published final and temporary (TD 9812) and proposed (REG-135734-14) tax regulations under section 7874 designed to fight tax avoidance associated with the inversion . . .
Singapore’s Inland Revenue Authority (IRAS) on January 12 published the fourth edition of its e-Tax Guide on transfer pricing. The new guidance includes a discussion . . .
Bermuda, Kazakhstan, and Côte d’Ivoire have joined the "Inclusive Framework on BEPS," to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . .
Cyprus' Ministry of Finance on December 22 announced that it will issue a decree setting out the requirements for country-by-country reporting . . .
The Luxembourg government on December 27 published new tax guidance for intragroup financing transactions. The guidance . . .
The European Court of Justice has today confirmed that Starbucks filed a suit in September challenging the European Commission's decision of October 21, 2015, which concluded that an advance pricing agreement . . .
Hong Kong's Inland Revenue Department on December 22 issued more guidance on country-by-country reporting for large multinationals, including . . .
The OECD on December 22 published a report on limiting base erosion involving interest deductions and other financial payments, updating . . .
The Australian Taxation Office, on December 22, published a draft goods and services ruling (GSTR 2016/D1) discussing the meaning of "Australian Consumer" for purposes of rules that . . .
India on December 21 set out a series of questions and answers clarifying the taxation . . .
Taiwan’s Ministry of Finance (MOF) has announced that on December 9 the Legislative Yuan passed a law imposing VAT on supplies of cross-border electronic services made to . . .
The US IRS has released final regulations (TD 9803) under section 367 which eliminate the favorable tax treatment of outbound transfers . . .
Australia Treasury has released a discussion paper seeking comments on whether the government should sign . . .
The Australian government on December 9 released its latest corporate tax transparency report, making public the 2014–15 tax details of 1,904 large . . .
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
The US IRS on December 13 published final tax regulations (T.D. 9796) under sections 6038A and 7701 that require wholly foreign-owned domestic disregarded entities to be treated as a domestic corporations, separate from their owners . . .
The UK, on December 9, published draft tax guidance to clarify aspects of hybrid mismatch legislation which will take effect January 1, 2017. The legislation, introduced . . .