Australia–MNE Tax

Asia-Pacific

Australian guidance addresses treatment of capital gains in computing foreign income offset limit: Australian Taxation Office→

September 8, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Asia-Pacific

Australian government advises that it will ask large entities to confirm information to be disclosed in legislatively mandated corporate tax transparency report next month: Australian Taxation Office→

August 25, 2020

Asia-Pacific

Australian alert addresses multiple entry consolidated groups that avoid capital gains tax through transfer of assets to an eligible tier-1 company prior to divestment: Australian Taxation Office→

August 24, 2020

Asia-Pacific

Draft Australian transfer pricing guidance addresses interest-free loans, debt vs. equity conundrum

August 19, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP, discuss August 12 draft transfer pricing guidance issued by the Australian Taxation Office outlining its proposed risk assessment of outbound interest-free loans made to related parties . . .

Asia-Pacific

Australia issues tax guidance on thin capitalization limitations

August 18, 2020

Dr. Harold McClure, a New York City economist, discusses August 12 guidance issued by the Australian Taxation Office that limits intercompany interest deductions . . .

Asia-Pacific

Australia addresses transfer pricing treatment of Covid-19 support payments

July 22, 2020

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium | AustralAsia LP discuss July 15 Australian Taxation Office guidance on the transfer pricing treatment of payments made under Australia’s JobKeeper program, which provides financial support to employers that have been materially affected by the Covid-19 pandemic . . .

Africa

Intercompany interest deductions in the extractive sector

July 15, 2020

Economist Dr. Harold McClure of New York City discusses the taxation of intercompany financing in the extractive sector, focusing on likely tax disputes concerning the financing of Australia’s Gorgon natural gas project, the UN’s recent guidance on transfer pricing in the extractive sector, and the ConocoPhillips and Chevron intercompany financing litigations . . .

Asia-Pacific

Australia claims Alcoa owes 921m (USD 640m) additional tax and interest in transfer pricing dispute, says alumina sales to Bahrain unit were underpriced: Brad Thompson / Financial review→

July 10, 2020

Asia-Pacific

Australia transfer pricing guidance addresses COVID-19 impact

June 24, 2020

Leslie Prescott-Haar and Sophie Day of TP EQuilibrium AustralAsia discuss June 9 Australian guidance on the impact of COVID-19 on transfer pricing . . .

Asia-Pacific

Tax guidance addresses mischaracterized arrangements and schemes connected with foreign investment into Australian entities: Australian Taxation Office→

May 29, 2020

Asia-Pacific

Australia updates GAAR guidance: Australian Taxation Office→

May 20, 2020

Asia-Pacific

Synthesized text of Australia-Norway tax treaty as modified by BEPS MLI published: Australian Taxation Office→

May 13, 2020

Asia-Pacific

Australian Taxation Office assesses Rio Tinto AUD $86.1m (USD 53.6m) for 2010–2016 alleging it sold underpriced aluminum to Singapore marketing hub: Peter Ker / Financial Review→

April 8, 2020

Asia-Pacific

Australia releases synthesized text of tax treaty with Canada as amended by the MLI: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australia increases the number of data validations required before computer system accepts country-by-country reports: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australia updates guidance on interpreting tax treaties: Australian Taxation Office→

March 20, 2020

Asia-Pacific

Australian High Court clarifies definition of “associate” in BHP Billiton tax dispute

March 19, 2020

Paul McNab, a Tax Controversy Partner at PwC Sydney, discusses the March 11 decision High Court of Australia in BHP Billiton Limited v Commissioner of Taxation [2020] HCA 5) where the Court addresses the definition of “associate” for tax purposes . . .

Asia-Pacific

Australia changes instant asset write off threshold, accelerates depreciation, defers tax payments in response to coronavirus emergency: Prime Minister of Australia→

March 18, 2020

Asia-Pacific

Synthesized text of Belgium-Australia tax treaty as modified by MLI published: Australian Taxation Office→

March 4, 2020

Asia-Pacific

Australia issues transfer pricing guidance on issues related to projects involving the use in Australian waters of non-resident owned mobile offshore drilling units: Australian Taxation Office→

February 19, 2020

Asia-Pacific

Australian tax agency reveals plan to scrutinize non-arm’s length arrangements involving intangible assets

February 5, 2020

David Lewis, Managing Director of Duff & Phelps Australia Pty Ltd., Melbourne, discusses Australian Taxation Office (ATO) transfer pricing guidance issued January 22 which provides examples of arrangements involving intangibles that the agency considers to not be arm’s length . . .

Asia-Pacific

Austrian coalition plan endorses corporate tax rate to drop from 25% to 21%: Reuters→

January 6, 2020

Asia-Pacific

Google settles Australian tax dispute spanning 2008–2018 for AUD 481.5m (USD 336.7): Ben Butler / The Guardian→

December 30, 2019

Asia-Pacific

Australia proposes clarifications to tax rules for hybrid mismatches

December 16, 2019

The Australian Taxation Office on December 13 issued exposure draft legislation clarifying aspects . . .

Asia-Pacific

Australia releases synthesized text of tax treaties with Ireland, India reflecting MLI changes

December 3, 2019

The Australian government on November 29 released the synthesized texts of tax . . .

Asia-Pacific

Australia addresses implementation of rule requiring entities to align asset value for thin cap purposes with financial statement value: Australian Taxation Office→

October 23, 2019

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Asia-Pacific

Australia defers expansion of reportable tax position filing to large private companies until 2020-21 financial year: Australian Taxation Office→

October 13, 2019

Asia-Pacific

Australian Taxation Office seeking full bench appeal of Glencore transfer price decision: Tom McIlroy / Financial Review→

October 7, 2019

Asia-Pacific

Australian tax office advises on transfer pricing for offshore drilling

September 27, 2019

The Australian Taxation Office (ATO) on . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Asia-Pacific

Australia updates guidance on simplified transfer pricing recordkeeping: Australian Taxation Office→

September 17, 2019

Asia-Pacific

Australia: Glencore’s ‘big win’ for taxpayers on transfer pricing

September 12, 2019

Ruth Butter and Stefan Sunde at TP EQuilibrium AustralAsia discuss Glencore’s recent win in a transfer pricing dispute before the Federal Court of Australia . . .

Asia-Pacific

Australia provides arm’s length debt test guidance

September 3, 2019

Leslie Prescott-Haar and Stefan Sunde at TP EQuilibrium AustralAsia discuss the Australian Tax Office’s August 28 draft guidance on applying the arm’s length debt test for thin capitalization purposes . . .

Asia-Pacific

First Look: Glencore wins Australian transfer pricing case

September 3, 2019

Glencore won an AUS $92m (USD 62m) transfer pricing dispute with the . . .

Asia-Pacific

Australian Federal Court in Burton approves 50% credit for US tax paid on capital gain that is 50% taxable in Australia: Deloitte→

August 29, 2019

Asia-Pacific

Australian tax authority disallows Shell’s AUD 2.2bn (USD 1.4bn) tax deduction for gas tenement purchases: Ben Butler / The Guardian→

August 27, 2019

Australia

Australian tax office addresses transfer pricing, debt-equity rule interaction

July 10, 2019

The Australian Tax Office on 4 June released guidance which deals with the interaction between the transfer pricing rules and the debt-equity rules, write Leslie Prescott-Haar & Stefan Sunde, TP EQuilibrium | AustralAsia LP . . .

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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