The EU Joint Transfer Pricing Forum (JTPF) has proposed modifications to the EU Arbitration Convention and revised Code of Conduct to better accommodate transfer pricing disputes. in a report released on its website, the JTPF . . .
The European Commission's Joint Transfer Pricing Forum (JTPF) has released draft papers on improving the functioning of the EU arbitration convention and the EU code of conduct on transfer pricing documentation. The drafts, released in November, were . . .
Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group services. The guidance was released in response to Action 10 of the OECD Base Erosion and Profit Shifting (BEPS) plan, which directs the OECD to develop transfer pricing rules or special measures "to provide protection against common types of base eroding . . .
The European Commission on Oct. 7 announced that it has opened an in-depth investigation into whether Luxembourg granted private rulings to an Amazon subsidiary with too favorable terms, potentially violating EU rules on state aid. The 2003 tax ruling, which is still in force, sets a methodology for the payment of a tax deductible royalty by Luxembourg-based Amazon EU Sàrl to a related limited liability. . .
The South Korean government, on August 6, announced a wide-ranging package of tax reform measures, including requirement that large companies spend a minimum amount on investments, wage increases, and dividend payments or face an additional tax of 10 percent
Responding to calls from the G-20 and civil society groups, the Irish government, on April 29, announced that it will undertake a ‘spillover analysis’ to research what effect Ireland’s tax system has on the economies of developing countries. The Irish government will engage consultants to assist with the evaluation and has launched a public consultation, asking interested parties to make submissions on the topic. SeePublic Consultation.
Tax officials from 104 jurisdictions attending the November 5-6 meeting of the OECD's Global Forum on VAT endorsed new OECD VAT/GST guidelines on the treatment of cross-border trade in services and intangibles and suggested that the OECD next consider taking on several new VAT . . .
The European Commission today announced that it has determined that advance pricing agreements granted to a Starbucks subsidiary by The Netherlands and to Fiat subsidiary by Luxembourg were illegal state aid because they sanctioned the allocation of too little profit to activities in those countries and . . .
The European Council on October 6 reached unanimous agreement on a directive that would require EU states to automatically exchange information about private tax rulings with other EU states. The agreement, reached at an ECOFIN meeting in Luxembourg, obliges . . .
Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
All EU states support the main objectives of the EU Commission proposal for mandatory automatic exchange of information on tax rulings, according to a report of the outcome of a June 19 ECOFIN meeting in Luxembourg. At the meeting, EU finance ministers also . . .
Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD's effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .
Materials that accompany a UK draft law suggest that OECD/G20 base erosion profit shifting (BEPS) guidance will recommend that country-by-country reporting data be disseminated using a tax treaty mechanism, vastly limiting the scope of the reform, tax campaigners say . . .
"China will comprehensively monitor the profit levels of foreign companies to make sure there is no base erosion and profit shifting," Zhang Zhiyong, deputy director of the State Administration of Taxation (SAT) said December 1, the government's news agency, Xinhua, has reported. Zhang also said that China intends to. . .
Kirill Roubalsky has joined the Moscow office of Dentons as a senior associate in the Tax and Customs practice. Roubalsky, fomerly with Pepeliaev Group, Schekin & Partners and Muranov, Chernyakov & Partners, specializes in tax litigation, general corporate and international tax law and tansfer pricing issues. Release
The European Commission, on June 11, announced that it is investigating whether individual transfer pricing rulings granted to Apple in Ireland, Starbucks in the Netherlands, and Fiat in Luxembourg sanctioned the allocation of too little profit to activities in those countries, thereby amounting to illegal state aid. The Commission has also initiated an infringement action against Luxembourg in connection with the matter.The decision is part of a wider investigation into whether tax rulings and . . .
-Update: The Luxembourg Finance Ministry, in a June 12 statement, said it would continue to defend against the Commission's charges of illegal state aid, and said it still has doubts about the legality Commission requests for information, see statement.
The Netherlands announced November 27 that it will appeal the EU Commission's October 21 ruling that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary amounted to illegal State aid because it sanctioned the allocation of too little taxable profit . . .
"Ireland will probably face censure from European authorities within months in relation to its tax dealings with Apple Inc.," write Gaspard Sebag and Joe Brennan of Bloomberg Business, quoting unnamed sources. See:Bloomberg Business.
US Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew asking Treasury stop work on a regulation project to . . .
Canada signed 31 advanced pricing arrangements (APAs) in FY 2014/2015, the most in five years, according to data released August 20 by the Canadian Revenue Agency (CRA). A total of 29 bilateral and 2 unilateral . . .
China and South Korea have signed a bilateral advance pricing agreement, the Chinese goverment announced in a June 23 English-language release. The signing took place during a Sino-South Korea tax commissioners meeting . . .