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New Irish fund vehicle permits US check-the-box election

March 11, 2015

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 . . .

US–Kazakhstan competent authority agreement published

February 1, 2015

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 . . .

OECD to involve developing nations in BEPS project

November 12, 2014

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.

OECD guidance proposes simplified transfer pricing treatment for low value-adding intra-group services

November 3, 2014

Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group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 . . .

Private tax rulings granted by Luxembourg to Amazon under EU scrutiny

October 7, 2014

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. . .

Australian official says six nations jointly investigating e-commerce firms; reviews ATO work on BEPS

May 22, 2014

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. . .

Irish government to investigate effect of its tax regime on developing nations

April 29, 2014

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. See Public Consultation.

BEPS digital economy work still at square one

April 23, 2014

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. . .
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