Ireland's Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle ("ICAV"), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .
The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries . . .
The OECD on January 12 released public comments to discussion drafts under the OECD's base erosion and profit shifting (BEPS) action plan which deal with the prevention of tax treaty abuse and with the artificial avoidance of permanent establishment (PE) status. Eighty comments were released on the tax treaty . . .
The Swiss Federal Council on December 17 submitted for consultation a bill proposing to replace its current debtor system of withholding to a system based on a paying agent principle. The consultation will run until March 31, 2015. See, release.
The EU Commission's new president, Jean-Claude Juncker, on November 27, survived a no-confidence vote in European parliament brought on account of the 'Lux leak" revelations that Luxembourg helped scores of multinationals avoid tax while he was prime minister. The censure motion . . .
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 . . .
The OECD will invite some developing nations to participate in OECD Committee on Fiscal Affairs (CFA) meetings, will hold regional consultations, and will work on capacity development in an effort to increase developing nation input in the OECD/G-20 base erosion profit shifting (BEPS) plan decision-making . . .
UPDATE: Philippines Joining OECD Committee on Fiscal Affairs: The Philippines will join the OECD Committee on Fiscal Affairs to work on a global response to BEPS beginning January 2015, the Philippines Department of Finance announced November 14. See, Philippines release.
Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group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 . . .
Ireland is expected to announce on October 14 that it will phase out the "Double Irish" tax loophole, reports Sam Schechner and Lisa Fleisher, The Wall Street Journal. See also, Padraic Halpin, Reutersand Arthur Beesley,Irish Times.
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. . .
Macau's Financial Services Bureau on Sept. 26 announced its support for the common reporting standard for automatic exchange of financial account information. Procedures will be initiated to amend Macua's laws to ensure timely compliance with the new standard, the agency said. Release.
The South African Revenue Service, on August 14, released a binding private ruling involving the proposed restructuring of a multinational group, concluding that a German Kommanditgesellschaft is a company for South African tax purposes and that the proposed restructuring did not give rise to tax, including capital gains tax. BPR 178
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
Hong Kong and Korea, on July 8, signed an agreement for the avoidance of double tax and fiscal evasion with respect to taxes on income . Under the agreement, the Korean withholding tax on interest . . .
An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.Mark Konza, ATO Deputy Commissioner, International, said that Australia was "currently involved in a cooperative compliance approach" with five other nations. The collaboration led to the production of an. . .
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.
Members of the OECD task force charged with crafting rules to address the tax challenges of the digital economy still disagree on fundamental issues associated with the project. Speaking April 23, Edourad Marcus, co-chair of the task force, said members are still debating whether they should recommended modifications to the corporate income tax through. . .