Multinational
Transfer Pricing
Americas
Europe
Americas
US IRS reassessing transfer pricing strategy following court losses, unable to sign all country-by-country reporting CAAs
US IRS and Treasury officials joined tax practitioners and corporate tax executives today to discuss key international tax and transfer pricing developments at the 30th Annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the Internal Revenue . . .
Americas
Europe
Europe
EU doubles down on State aid theory, orders Amazon to pay Luxembourg taxes
Dimitrios Kyriazis of the New College of the Humanities and University of Oxford discusses today’s news that the EU Commission has adopted a negative decision in the Amazon fiscal State aid case and the Commission’s argument that a departure from the arm’s length principle amounts to the conferral of an advantage to the recipient . . .
Cyprus
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New ‘toolkit’ addresses lack of transfer pricing comparables
The “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and the World Bank – today published the final version of a toolkit designed to provide developing . . .
Americas
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OECD officials provide update on international tax agenda
Tax officials, during a March 28 webcast, discussed the OECD’s international tax agenda, including plans to release tax and transfer pricing guidance and promote . . .
Europe
Italy publishes tax rules implementing country-by-country reporting for large multinationals
Davide Anghileri of the University of Lausanne discusses Italy’s new country-by-country reporting requirements for large multinationals . . .
Europe
Malaysia
Malaysia joins BEPS inclusive framework to combat multinational tax avoidance
The OECD today announced that Malaysia has joined the “Inclusive Framework on BEPS,” which is a group of countries that have pledged to implement tax measures to combat multinational tax avoidance designed by OECD and G20 countries in its . . . .
Americas
US IRS allows early parent-surrogate filing for country-by-country reporting
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 . . .
Europe
Europe
Swiss Federal Council agrees to exchange of country-by-country reports on multinationals
Davide Anghileri of the University of Lausanne discusses the Swiss Federal Council’s adoption on November 23 of the multilateral agreement on the exchange of country-by-country reports and a federal act required for its implementation . . .
Americas
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Sanders joins Dems urging public country-by-country tax reporting for US multinationals
US Democratic presidential candidate Sen. Bernie Sanders (I-VT) and three Senate colleagues on June 8 urged the Obama administration to require public disclosure of country-by-country tax reports of large multinational . . .
Europe
Americas
Multinational
Americas
US planning international tax guidance on BEAT, GILTI, transition tax, Treasury official says
The US intends to issue proposed tax regulations next month addressing the section 965 transition tax followed by year-end guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury during the 2018 OECD International Tax Conference, held . . .
Europe
Americas
Asia-Pacific
Australia: related party financing faces heightened tax scrutiny
Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO’s risk assessment framework for cross-border related party financing . . .
Europe
EU Parliament proposal would extend public country-by-country reporting to more multinationals
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 . . .
Europe
Europe
Europe
Leaked EU directive makes CCTB/CCCTB tax scheme mandatory for large multinationals
A proposed directive for an EU common corporate tax base (CCTB), to be presented by the EU Commission next week, and the EU’s planned common consolidated corporate tax base (CCCTB) proposal, would be mandatory for multinational groups operating in the EU that have annual revenue exceeding €750 million . . .
Asia-Pacific
Pakistan signs multilateral agreement to fight tax evasion and avoidance
Pakistan today became the 104th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the . . .
Americas
Countries targeted US companies in BEPS project to increase tax revenue, US Treasury official charges
Countries participating in the OECD/G20 base erosion profit shifting (BEPS) project sought to rewrite international tax rules for the digital economy and for intellectual property to increase their tax take at the expense of the United States, Robert Stack, Treasury deputy assistant secretary. . .
Asia-Pacific
Europe
EU Parliament committee pushes for State aid review of multinationals’ country-by-country tax reports
The EU Parliament’s Economic and Monetary Affairs Committee on Tuesday approved a report proposing to give the EU Commission full access to country-by-country reports of multinationals that are . . .
Asia-Pacific
Japan enacts tax reform
Professor Masao Yoshimura of Hitotsubashi University provides an overview of the corporate tax and transfer pricing changes in Japan’s tax reform 2016, enacted on March 29. . .
From the Firms
Europe
Germany, France making progress on EU-wide corporate tax system
Konstantin Sakuth of Linklaters LLP, Munich, provides an update of Germany and France’s plan to jointly develop a common corporate tax base for Europe, noting June 5 comments made by Germany’s Martin Kreienbaum at the OECD Tax Conference in Washington and a May 31 German government announcement on the topic . . .
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