Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission's State aid decision against Ireland, published today in summary form, noting that Apple's arguments diverge somewhat from Ireland's arguments. . .
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 . . .
See: Bloomberg BNA.
Multinationals, particularly the largest firms, take advantage of profit shifting to low tax rate countries, mismatches between country tax systems, and preferential tax regimes to significantly lower their tax bills, though countries that strengthen their antiavoidance laws may be able . . .
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 . . . .
The OECD today released documents to implement peer review of countries' compliance with minimum standards devised under OECD/G20 base erosion and profit shifting (BEPS) Action 13, dealing with country-by-country reporting, and . . .
The OECD has today asked global businesses to assess the mutual agreement procedure (MAP) for resolving tax treaty disputes in Austria, France, Germany, Italy . . .
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 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 . . .
In a surprising move, PwC has agreed to hire more than 600 members of GE's tax team from around the world and provide tax services to GE on . . .
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 . . .
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 . . .
Joel Cooper of DLA Piper discusses a new World Bank handbook designed to assist developing country tax administrations with the implementation of transfer pricing rules. . .
Dimitrios Kyriazis, a Doctoral Researcher in Law at the University of Oxford, analyzes the European Court of Justice's judgment in the so-called Spanish goodwill cases, released December 21, and addresses the ruling's impact on the Apple, Fiat, Starbucks State aid cases . . .
The OECD on December 22 published a report on limiting base erosion involving interest deductions and other financial payments, updating . . .
Australia Treasury has released a discussion paper seeking comments on whether the government should sign . . .
The British Virgin Islands will join the OECD/G20 Inclusive Framework, pledging to adopt and work toward the implementation of the minimum international tax standards in the OECD/G20 Base Erosion Profit Shifting . . .
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
Mansi Seth, head of Nishith Desai Associates’ US practice, and Ashish Sodhani, a senior member of the firm's international tax practice, discuss the renegotiated India-Cyprus tax treaty, which provides for source-based taxation of capital gains arising from alienation of shares . . .
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .