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Australia

Asia-Pacific

Australia releases guidance on how the tax authority recovers a tax debt of a debtor located in a foreign country: Australian Taxation Office→

August 15, 2019
Asia-Pacific

Australian taxation office explains hybrid mismatches through structured arrangements

July 25, 2019

The Australian Taxation Office (ATO) on July 25 issued new guidance on the meaning of . . .

Asia-Pacific

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

August 9, 2019

The Australian government on August 9 published the synthesized texts of . . .

Asia-Pacific

Australia considering patent box tax break for IP, Treasurer Josh Frydenberg says: Denham Sadler / InnovationsAus.com→

June 24, 2019
Asia-Pacific

Australia considers requiring more taxpayers to file reportable tax position schedule

July 11, 2019

The Australian Taxation Office on July 8 launched a consultation on . . .

Asia-Pacific

Australian High Court confirms that tax office can use leaked documents including those obtained from law firms: Australian Taxation Office→

August 14, 2019
Asia-Pacific

Jones Day’s nabs eight Clayton Utz tax lawyers for Melborne office

May 13, 2019

Eight tax Clayton Utz tax controversy lawyers, led by Dr. Niv Tadmore,  have joined . . .

Asia-Pacific

BHP settles dispute with Western Australia over taxation of royalties on iron ore sold though Singapore hub: Reuters→

July 1, 2019
Asia-Pacific

Synthesized text of Australia-Singapore tax treaty published: Australian Taxation Office→

May 25, 2019
Asia-Pacific

Australia issues final tax guidance on central management and control test for foreign companies

June 27, 2018

The Australian Taxation Office has issued final taxation guidance setting out how the . . .

Asia-Pacific

Australian tax authority settles BHP transfer pricing dispute over marketing hub

November 19, 2018

The Australian Taxation Office (ATO) today confirmed that it has reached a settlement with mining giant BHP to resolve a transfer pricing dispute . . .

Asia-Pacific

Australian Taxation Office to focus on migration of IP offshore, official says: Nassim Khadem / The Sydney Morning Herald→

July 18, 2018
Asia-Pacific

Australia consults on gas transfer pricing arrangements, submissions due June 14: Australian Treasury→

April 10, 2019
Asia-Pacific

Australian government introduces bill extending GST to imported low value goods→

February 27, 2017

See: Draft bill. See also: Draft Law Companion Guideline LCG 2017/D2.

Asia-Pacific

UK and Australia’s different PE profit attribution approach yields double taxation and nontaxation: Celeste Black / SSRN→

June 28, 2017
Asia-Pacific

McDonald’s could run afoul of Australia’s diverted profits tax: Nassim Khadem / The Sydney Morning Herald→

June 1, 2017
Asia-Pacific

Australian tax office seeking to fast-track key court disputes with multinationals

April 21, 2016

The Australian Tax Office (ATO) is working with the Federal Court in an effort to “fast-track” the resolution of strategically important tax cases, Tax Commissioner Chris Jordan said April 21 at a Senate committee hearing on multinational corporation . . . 

Asia-Pacific

Australian tax office issues guidance on targeted integrity rules for hybrid mismatches

April 9, 2019

The Australian Taxation Office (ATO) on April 5 issued . . .

Asia-Pacific

Australia updates tax guidance on central managment and control test

December 6, 2018

The Australian Taxation Office on December 5 issued an update to draft guidance . . .

Asia-Pacific

Australia’s diverted profit tax clarified in new guidance

December 21, 2017

The Australian Taxation Office (ATO) on December 18 published two sets of guidance further clarifying it’s a diverted profits tax on large multinationals. The tax . . .

Asia-Pacific

Australian transfer pricing guidance on marketing, sales and distribution hubs released

January 17, 2017

Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO’s approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .

Asia-Pacific

Singapore, Australia sign agreement to share information to combat tax evasion

September 7, 2016

Singapore and Australia’s tax offices have signed an agreement to share data in an effort to crack down on tax evasion, the Australian tax authority. . .

Asia-Pacific

Australian bill imposes GST on digital products and other intangibles supplied by nonresidents

February 10, 2016

Australia’s Treasurer on February 10 introduced into Parliament a bill that would impose the 10 percent goods and services tax (GST) to all supplies by nonresidents to Australian consumers except for supplies of goods and real property. A second measure . . .

Asia-Pacific

Australian tax office issues guidance on thin cap arm’s length debt test

April 9, 2019

The Australian Taxation Office on April 5 issued a draft taxation ruling (Tr 2019/2) addressing . . .

Asia-Pacific

Multilateral tax treaty enters into force in Singapore affecting 14 bilateral treaties

April 1, 2019

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered . . .

Asia-Pacific

Australia expects large tax recoveries from seven multinational firm audits, Jordan says

March 16, 2017

The Australian Taxation Office (ATO) expects to conclude tax audits of at least seven major multinational firms by June 30, likely assessing combined tax liabilities in excess . . . 

Asia-Pacific

Australian PM drops plan to cut large corporation tax rate from 30 percent rate to 25 percent: Cathy Zhang / The Epoch Times→

August 23, 2018
Americas

New Zealand proposes rules to combat multinational tax avoidance through use of hybrid mismatches

September 6, 2016

The New Zealand government has today released for discussion proposed measures to prevent multinational corporations from avoiding tax through use of hybrid mismatch . . .

Asia-Pacific

Australian law adopting MLI law passes parliament

August 22, 2018

Australian legislation adopting the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) was passed . . .

Asia-Pacific

Australian tax authority finalizes related party financing guidance

December 21, 2017

The Australian Taxation Office on December 18 issued final guidance outlining its compliance approach to related party financing arrangements. Practical Compliance Guideline 2017/4 . . .

Asia-Pacific

Australia to impose GST on digital products, low value imported goods: EY→

June 29, 2017
Asia-Pacific

Australia sets enhanced cooperation with tax office as condition for foreign investment

February 22, 2016

Australian Treasurer Scott Morrison on February 22 announced that he will use his powers to block investment to force large multinationals and other foreign investors pay tax on Australian . . .

Asia-Pacific

Australia publishes synthesized text of tax treaty with Slovak Republic as affected by the MLI: Australian Taxation Office→

April 9, 2019
Asia-Pacific

Australian Court rejects Chevron’s appeal in transfer pricing dispute

April 21, 2017

Australia’s Full Federal Court today dismissed Chevron’s appeal in a transfer pricing case involving intercompany loans, handing the Australian Taxation Office (ATO) a key victory. By unanimous judgment, the full bench . . .

Asia-Pacific

Australian tax office warns about schemes to avoid multinational antiavoidance law, ’round robin’ financing

September 16, 2016

The Australian Taxation Office (ATO) is warning multinationals that it will contest a tax planning maneuver designed to thwart Australia’s new Multinational Anti Avoidance Law (MAAL) as well as ’round robin’ type intragroup financing arrangements that generate . . .

Asia-Pacific

Australia 2017 year-in-review: tax authority takes aim at large multinational business

January 7, 2018

Zara Ritchie and Natalya Marenina of BDO take a look back at the most significant Australian international tax developments of 2017 — including the new focus on significant global entities, transfer pricing documentation, diverted profits tax, and cross-boarder financing — and consider what 2018 is likely to bring . . .

Asia-Pacific

Chris Jordan reappointed Australian Commissioner of Taxation

April 27, 2017

Chris Jordan’s term as Australian Commissioner of Taxation (ATO) has been extended through. . .

Asia-Pacific

Australia issues guidelines for simplified transfer pricing record-keeping

February 23, 2017

The Australian Taxation Office (ATO), on 22 February, released Practical Compliance Guideline PCG 2017/2 (PCG 2017/2), outlining simplified transfer pricing record-keeping options to minimise record-keeping for eligible taxpayers, writes Davide Anghileri . . . 

Asia-Pacific

Australian budget includes UK-style diverted profits tax, anti-hybrid rules

May 3, 2016

The Australian government on May 3 released its 2016–17 budget, announcing several measures to crack down on multinational tax avoidance, including a tough new diverted profits tax (DPT), anti-hybrid and transfer pricing rules patterned after . . .

Posts navigation

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What’s Next

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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
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  • 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
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    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
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • UN releases updated model tax treaty adding new technical services fees article by Julie Martin | posted on May 22, 2018
  • Australian transfer pricing guidance on marketing, sales and distribution hubs released by Davide Anghileri | posted on January 17, 2017

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