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Africa

Africa

South Africa’s Davis Tax Committee recommends way forward on BEPS

November 14, 2017

South Africa’s Davis Tax Committee on October 13 published its second and final report on base erosion and profit shifting (BEPS). This new report replaces its earlier report on the topic. The purpose . . .

Africa

Mauritius MLI choices allow it to remain a tax haven: Tax Justice Network→

July 13, 2017
Africa

Report compares 12 countries’ tax rules for holding companies: Loyens & Loeff→

April 14, 2017
Africa

Kenya and Mauritius sign new tax treaty following court nullification of earlier agreement

April 15, 2019

The Kenyan and Mauritius governments have signed a new tax treaty following the Kenya High Court invalidation last month of a 2012 treaty between two nations in an action brought by Tax Justice Network Africa . . .

Africa

South Africa updates guidance on taxation of foreign dividends

March 22, 2018

The South African government today released an updated version of its draft interpretation note on the taxation of foreign . . .

Africa

Ireland, Ghana tax treaty signed

February 14, 2018

A new double tax treaty between Ireland and Ghana was signed on February 7, Irish Revenue today announced. Procedures are now underway . . .

Africa

Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama, Tunisia sign multilateral treaty on tax avoidance

January 24, 2018

Officials from Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama, and Tunisia today signed a multilateral instrument designed to allow the countries to quickly strengthen their tax treaties with other countries, adding provisions to curtail tax avoidance and improve . . .

Africa

Russia, Malta, Mauritius, Hungary, Gabon, Indonesia, Lithuania sign tax agreement on exchange of country-by-country reports

January 28, 2017

In an effort to provide their tax administrations with tools to combat corporate tax avoidance through transfer pricing, officials from 7 more countries have signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large . . . 

Africa

Singapore-South Africa tax treaty enters into force

December 22, 2016

A new Singapore-South Africa tax treaty entered into force on December 16, Singapore’s Ministry of Finance . . .

Brazil

UN tax committee to consider major updates to transfer pricing manual, model tax treaty

October 10, 2016

The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . . 

Africa

Brazil consults on MAP changes: Alex Jorge & Humberto Marini / DLA Piper→

September 30, 2016

See: DLA Piper.

Africa

Singapore and Ethiopia sign tax treaty, text available

August 24, 2016

Singapore and Ethiopia signed a tax treaty on August 24, Singapore’s Inland . . .

Africa

Morocco joins “Inclusive Framework” to fight MNE tax avoidance

March 5, 2019

Morocco has joined the “Inclusive Framework on BEPS,” a coalition of now 129 countries working on global . . .

Africa

Singapore, Nigeria income tax treaty enters into force 

August 3, 2018

The Inland Revenue Authority of Singapore has today announced that a comprehensive tax treaty signed between Singapore and Nigeria has been ratified . . .

Africa

Dividends paid by Netherlands company to South Africa parent exempt from withholding, court rules: EY→

September 11, 2017
No Picture
Africa

Portugal must grant company at least partial tax deduction for dividends received from Tunisian or Lebanese subsidiaries, EU court rules

November 29, 2016

Davide Anghileri, a lecturer at the University of Lausanne, discusses a Court of Justice of the European Union decision which concludes that Portugal’s current practice of denying Portuguese companies a deduction for intercompany dividends received from Tunisian or Lebanese subsidiaries violates EU law . . .

Africa

300 economists call for public country-by-country reporting, disclosure of company and trust beneficial owners: Oxfam International→

May 9, 2016

See: Oxfam International.

Africa

Mauritius budget alters foreign tax credit rules: Lubna Kably / Times of India→

June 20, 2018
Africa

Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance

November 26, 2016

Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .

Africa

New protocol allows India to tax capital gains from sales by Mauritius residents of Indian company stock

May 10, 2016

India and Mauritius today signed a protocol to their 1983 tax treaty, revising the tax treatment of capital gains on sales by Mauritius residents of . . .


UPDATE: Text of the India/Mauritius protocol published: The text of the new protocl has been published on the Mauritius goverment website. See: Protocol.

Africa

Trade group challenges Slovak tax on foreign retailers: ESM Magazine→

February 4, 2019
Americas

Companies face setback in challenge to District of Columbia’s use of Chainbridge transfer pricing method

February 14, 2018

Mark Nachbar and Mary Bernard of Ryan, LLC note the release of a surprising January 26 ruling in actions, brought by Hess, Exxon, and Shell, challenging the District of Columbia’s use of transfer pricing software developed by Chainbridge Software to assess millions in tax liabilities against them . . .

Africa

Singapore, Tunisia sign new tax treaty

February 27, 2018

Singapore signed a tax treaty with Tunisia on February 27, the Inland Revenue Authority of Singapore has announced. Under the agreement . . .

Africa

Cameroon signs MLI to tackle tax avoidance by multinational enterprises

July 11, 2017

Cameroon’s Minister of Finance, Alamine Ousmane Mey, today signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and . . .

Africa

Turkey to adopt transfer pricing documentation rules including CbC reporting: EY→

March 24, 2016

See: EY.

Africa

India, Mauritius to soon discuss tax treaty amendment: Gireesh Chandra Prasad / Livemint→

August 28, 2017
Africa

Ireland initials tax treaty with Oman, treaties with Botswana, Ethiopia enter into effect

February 7, 2017

Ireland has concluded negotiations for a new tax treaty with Oman and expects the treaty to be signed shortly, Irish Revenue . . .

Africa

Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance

July 19, 2016

Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .

Africa

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

January 31, 2019

The OECD has published a progress report detailing whether countries are meeting their commitments to . . .

Americas

US IRS to deny accounting period changes that avoid tax on deemed repatriation

February 13, 2018

The US IRS today announced it will deny a change in the accounting period of some US companies’ foreign affiliates if the change results in avoidance of the US’s newly enacted transition tax, which deems a repatriation of US company’s existing offshore earnings. Rev. Proc. 2018-17 prevents . . .

Africa

Draft South African guidance details tax rules denying deduction for royalty payment on “tainted” IP

January 9, 2018

The South African Revenue Authority on January 9 issued draft guidance interpreting a 2009 law which denies a tax deduction for royalties paid to use “tainted” intellectual . . .

Africa

DLA Piper hires Andrew Lewis to run new South Africa tax practice

September 1, 2017

DLA Piper has launched a tax practice in Johannesburg, South Africa, and has appointed Andrew Lewis as its tax director, the firm . . .

Africa

South Africa issues draft guidance on deductions for scientific, technological R&D→

January 17, 2017

See: Draft Interpretation Note 50.

Americas

Bermuda, Kazakhstan, Côte d’Ivoire join BEPS group fighting cross-border tax avoidance

January 6, 2017

Bermuda, Kazakhstan, and Côte d’Ivoire have joined the “Inclusive Framework on BEPS,” to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . . 

Australia

31 nations sign agreement on exchange of country-by-country transfer pricing reports

January 27, 2016

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .

Africa

UK requires companies in Caymans, BVI, other territories, to publicly disclose ownership

May 2, 2018

Britain’s overseas territories, including the tax havens of Cayman Islands, British Virgin Islands, and Bermuda, must introduce publicly accessible registers of the beneficial ownership of companies located in their jurisdictions before 2021 or the UK will require them to do so, a law approved by UK Parliament . . .

Africa

Australia releases draft law adopting BEPS MLI, seeks to amend 30 bilateral tax treaties 

February 8, 2018

The Australian government on February 8 released for public comment a draft law that would give the force of law to a multilateral tax treaty designed to amend about 30 of Australia’s tax treaties with other . . .

Africa

South African tax bill amends hybrid instrument rules, eliminates planned withholding on service fees

July 18, 2016

Peter Dachs of ENSafrica, Cape Town, discusses proposed revisions to South Africa’s tax law, released 8 July, that would reverse the planned introduction of withholding tax on service fees and that would modify the tax treatment of hybrid debt, share incentive schemes, and trusts that provide interest-free loans . . .

Africa

Senegal signs multilateral agreements to fight tax avoidance and evasion

February 5, 2016

Senegal on February 4 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 93rd jurisdiction to sign the document, and the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country . . .

Posts navigation

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
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    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 2020

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