The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Japan and Russia have begun negotiations to amend their tax treaty, Japan's Ministry of Finance has announced. The . . .
Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Canada's Federal budget 2017, released today, proposes to amend the Income Tax Act to prevent income from the insurance of Canadian risks from being shifted to a foreign branch of a Canadian life insurer . . .
Switzerland and Pakistan signed a tax treaty on March 21, Switzerland's Federal Council . . .
Carlo Fassbinder is Luxembourg's new Director of Taxation at the Ministry of Finance, Luxembourg's Ministry of Finance today announced. Fassbinder was previously head of retail and corporate . . .
"Rollback" of a transfer pricing method to resolve disputes in previous open tax years is permitted for bilateral advance pricing. . . .
Hong Kong signed treaties with six countries on March 16 for the automatic exchange of financial account information (AEOI) in tax. . .
The Mauritius Revenue Authority has advised that Mauritius has signed tax treaties . . .
Davide Anghileri of the University of Lausanne discusses tax guidance issued by the Italian Revenue Agency clarifying Italy's patent box regime, the tax credit for research and development (R&D) activities, and the tax credit for new business assets. . . .
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .
The Australian Taxation Office (ATO) expects to conclude tax audits of at least seven major multinational firms by June 30, likely assessing combined tax liabilities in excess . . .