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Malaysia joins BEPS inclusive framework to combat multinational tax avoidance
The OECD today announced that Malaysia has joined the “Inclusive Framework on BEPS,” which is a group of countries that have pledged to implement tax measures to combat multinational tax avoidance designed by OECD and G20 countries in its . . . .
Asia-Pacific
Singapore-India protocol modifying capital gains taxation enters into force
A protocol to the Singapore-India tax treaty entered into force on February 27, Singapore’s Inland Revenue Authority has announced. One aim of the . . .
Americas
US IRS allows early parent-surrogate filing for country-by-country reporting
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 . . .
Americas
US-Cambodia FATCA IGA enters into force
The US Treasury today announced on its website a Model 1 FATCA intergovernmental agreement (IGA) signed the US-Cambodia entered into . . .
Europe
Asia-Pacific
Hong Kong-Romania tax treaty enters into force
Hong Kong’s Inland Revenue Service, on December 9, announced that a new tax treaty with Romania entered into force on . . .
Europe
Swiss Federal Council agrees to exchange of country-by-country reports on multinationals
Davide Anghileri of the University of Lausanne discusses the Swiss Federal Council’s adoption on November 23 of the multilateral agreement on the exchange of country-by-country reports and a federal act required for its implementation . . .
Asia-Pacific
China names Xiao Jie as Finance Minister
The Chinese government has appointed Xiao Jie as its new Finance Minister, China’s . . .
Americas
Europe
Ireland’s Budget 2017 (again) affirms 12.5 percent corporate tax rate, addresses “section 110” firms
Professor James Stewart of Trinity College, Dublin, discusses Ireland’s Budget 2017 and the Minister for Finance’s accompanying address, delivered today, which affirmed Ireland’s intent to maintain a low corporate tax rate and address the taxation of financial intermediaries known as section 110 firms . . .
Asia-Pacific
Japan’s tax treaty with Germany, protocol with India, to enter into force
Japan’s Ministry of Finance today announced that two tax agreements will enter into force: a tax treaty with Germany and a protocol to a tax treaty with India. Notifications . . .
Europe
Draft German tax law would allow use of losses on ownership change, boosting venture capital industry
International tax professional, Ninja-Antonia Reggelin, discusses a proposed German law currently under debate that would allow corporations to use losses following a change of shareholders . . .
Asia-Pacific
Asia-Pacific
Asia-Pacific
India adopts controversial tax rules for valuing indirect transfers of assets
Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Meyyappan Nagappan, a senior member of the international taxation team in the firm’s Mumbai office, discuss new guidance issued by the Indian tax authority to be used to determine the fair market value of indirect transfer of assets, stating that several aspects of the new rules are contentious and could lead to litigation . . .
United Kingdom
Americas
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Sanders joins Dems urging public country-by-country tax reporting for US multinationals
US Democratic presidential candidate Sen. Bernie Sanders (I-VT) and three Senate colleagues on June 8 urged the Obama administration to require public disclosure of country-by-country tax reports of large multinational . . .
Asia-Pacific
Hong Kong tax guidance covers new income tax exemption for private equity funds
Hong Kong’s Inland Revenue Department on May 31 issued revised tax guidance to reflect changes enacted in 2015 that extend the exemption from Hong Kong . . .
Europe
France’s rules for taxing dividends from nonresident subsidiaries violate EU law, Commission says
The European Commission has today charged that France’s scheme for taxing of dividends from nonresident subsidiaries is discriminatory, and has asked France . . .
Europe
Americas
Canadian subsidiary may deduct interest on intercompany loan, court rules
Carrie Smit, a partner with Goodmans LLP, Toronto, analyzes the Canadian Federal Court of Appeals March 4 decision in The TDL Group Co. v. The Queen, which concluded that a Canadian company is entitled to deduct interest on an intercompany loan used to acquire shares of its US subsidiary. . .
Europe
The EU and Monaco initial tax information exchange agreement
The EU Commission and Monaco on February 22 initialed an agreement that would require automatic exchange bank account information on each other’s residents, the EU Commission has . . .
Europe
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