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G7 leaders agree to arbitration for double tax disputes, say OECD should monitor BEPS implementation

June 8, 2015

G7 leaders, in a joint declaration issued June 8, made a "commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment." The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .

UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders' expression of support for compulsory binding arbitration in multinational tax disputes "deeply troubling," stating . . .

Tax officials at BEPS hearing reject business reps’ interest deduction proposal

February 18, 2015

Government and OECD tax officials at a February 17 OECD hearing suggested that, contrary to business representative assertions, a 30 percent of EBITDA fixed ratio is too high to effectively combat excessive multinational corporation interest deductions. Officials suggested that a lower percentage is appropriate for guidance on interest deductions being drafted under the OECD/G-20 base erosion and profit shifting (BEPS) plan. The day-long hearing concerned draft BEPS guidance under action 4, released December 18, that would limit . . .

UAE set to sign FATCA Model 1 IGA

February 16, 2015

The United Arab Emirates will complete and sign a Model 1 FATCA IGA this month and will send the agreement electronically to the US IRS in September 2015, UAE HE Younis Haji Al Khoori, Undersecretary of the Ministry of Finance told reporters February 15. The UAE had reached an agreement . . .

Singapore and US sign Model 1 FATCA IGA

December 11, 2014

Singapore and the US on December 9 signed a FATCA Model 1 Intergovernmental Agreement (IGA), following the initialing of the agreement May 5, the Inland Revenue Authority of Singapore has announced. The IGA is designed to simplify FATCA information reporting for Singapore financial institutions.  See, Singapore release

Crimea residents receive new tax breaks

December 2, 2014

Russian President Vladimir Putin on December 1 signed addendums to the country’s tax code providing enhanced tax benefits to residents of the free economic zone in Crimea, Russian news agency TASS has reported. Under the new provisions . . .

Jersey and Romania sign TIEA

December 2, 2014

​Jersey and Romania on December 1 signed a tax information exchange agreement (TIEA) at the Romanian Embassy in London, the government of Jersey has . . .

Australia’s tax office revokes six APAs

November 7, 2014

The Australian tax office (ATO) has revoked six advance pricing agreements (APAs) with multinationals within the last six months because the government had been misled and the companies were engaging in aggressive tax planning, reports Nassim Khadem of the Brisbane Times in a November 7 report, quoting ATO deputy commissioner, Mark Konza. Konza also said the ATO is reviewing the activities of 80 high risk multinationals. See,  Brisbane Times.

US IRS notes new Form1042-S on FATCA website

November 3, 2014

The US IRS on October 15 posted a "recent development" to the TY2014 Instructions for Form 1042-S, as follows: "The 2014 Form 1042-S posted to IRS.gov on 04/02/2014 supersedes the 2014 Form 1042-S posted to IRS.gov on 03/12/2014. We are re-posting this form to correct the formatting of the recipient's address in order to facilitate the mailing of this form to taxpayers." See, FATCA website.

Ireland to close “double Irish,” but not until 2020 for existing arrangements

October 14, 2014

Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced.   Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .
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