Bhavik Timbadia and Hussain Sunel of BMR & Associates LLP discuss the newly revised draft UN Practical Manual on Transfer Pricing for Developing Countries, focusing on the India chapter, which reveals Indian tax authorities' current transfer pricing positions, including some surprising views on low value adding intra-group services . . .
The ECJ Advocate General in a January 19 opinion concluded that France’s use of GAAR to deny a withholding tax exemption for dividends distributed by a French company to its Luxembourg parent is incompatible with EU law, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne . . .
Adam Szubin will serve as Acting Secretary of the US Treasury effective immediately, Treasury announced in a . . .
See: White & Case.
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 . . .
Davide Anghileri of the University of Lausanne discusses Italy's January 17 release of its first investment ruling, which clarifies when a logistics hub located in Italy is a permanent establishment and covers the VAT treatment of goods flowing through such hubs . . .
The US Treasury Department today updated its FATCA website, reporting that Bahrain and the US signed a Model 1 intergovernmental . . .
The governments of Japan and Latvia today signed a their first tax treaty, Japan's Ministry of Finance has announced. The agreement, signed in Tokyo, would exempt royalties . . .
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus signed a tax treaty on . . .
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 Netherlands' Director of General Tax Administration, Dr. JAJ (Hans) Leijtens, has resigned his post, the Netherlands government . . .
Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO's approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .
Sriram Govind of the Institute for Austrian and International Tax Law discusses reports that India will not renegotiate its tax treaty with the Netherlands, as it did with Mauritius, Cyprus, and Singapore, and addresses the impact of the countries' expected signing of the BEPS multilateral instrument . . .
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 . . .
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 . . .
See: The Guardian.