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Australia

Asia-Pacific

Australia proposes changes to tax consolidation rules

September 11, 2017

The Australian government today proposed fixes to its tax consolidation rules to alter unintended tax . . .

Asia-Pacific

Australia proposes to extend MAAL to foreign trusts, partnerships

February 12, 2018

The Australian government today issued draft legislation and an explanatory memorandum proposing to extend its Multinational Anti-Avoidance Law (MAAL) to prevent taxpayers . . .

Asia-Pacific

Australia: related party financing faces heightened tax scrutiny

May 29, 2017

Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO’s risk assessment framework for cross-border related party financing . . .

Asia-Pacific

Australian tax guidance clarifies new hybrid mismatch law

December 19, 2018

The Australian Taxation Office today issued a draft law companion . . .

Asia-Pacific

Australia planning tax increase for multinational digital firms, R&D tax incentive changes

May 8, 2018

The Australian government intends to write new laws to tax digital businesses, crack down on research and development (R&D) tax incentive abuse, and revise the thin cap provisions, among other initiatives, budget documents released today . . .

Asia-Pacific

Australia extends local filing deadline for multinationals: PwC→

May 7, 2018
Asia-Pacific

Australia: draft tax ruling addresses central management and control test for tax residency

March 30, 2017

The Australian Taxation Office (ATO) has released a draft taxation ruling setting out the ATO’s view on when a foreign incorporated company is considered an Australian tax resident under the central management and control test, writes Davide Anghileri. . . .

Asia-Pacific

Australian tax guidance addresses the MAAL

July 6, 2018

The Australian government today released guidance further clarifying the Multinational Anti-Avoidance Law (MAAL), which is designed to shut down schemes . . .

Asia-Pacific

David Lewis joins Duff & Phelps’ Australian transfer pricing practice 

March 5, 2018

David Lewis has joined Duff & Phelps’ transfer pricing practice in Melbourne, Australia as managing . . .

Asia-Pacific

Australia’s transparency report shows one third of large businesses paid no tax

December 7, 2017

The Australian Taxation Office (ATO) today published its corporate tax transparency report, detailing revenue, taxable income, and tax paid by more than 2,000 large companies operating in Australia for the tax year 2015-16, The report provides data . . .

No Picture
Asia-Pacific

Australian bill would deny lower tax rate to passive investment companies

September 22, 2017

The Australian government has introduced a bill providing that passive investment companies will not qualify for . . .

Asia-Pacific

Australia weighs adoption of new OECD BEPS transfer pricing standards

February 11, 2016

The Australian Treasury on February 11 opened a consultation on whether Australia should adopt into law final OECD/G20 base erosion profit shifting (BEPS) transfer pricing . . .

Asia-Pacific

Australian bill closing tax consolidation regime loopholes passes Parliament

March 22, 2018

The Australian government today announced the passage through Parliament of the Treasury Laws . . .

Americas

Eight countries launch ICAP pilot to jointly assess multinational firm tax positions, handbook released

January 24, 2018

Tax officials from eight countries — Australia, Canada, Italy, Japan, the Netherlands, Spain, UK, and US — on January 23 launched in Washington, DC, a pilot program to jointly assess the tax and transfer pricing positions of multinational . . .

Asia-Pacific

Australia budget 2017 hits hybrid regulatory capital tax abuse, extends MAAL

May 9, 2017

In a further effort to curtail tax avoidance by multinationals, Australia will introduce hybrid mismatch provisions applicable to banks and insurance companies and tighten . . .

Asia-Pacific

Australia focusing on pharmaceutical industry tax, transfer pricing practices

September 8, 2017

The Australian Taxation Office (ATO) announced September 7 that it is conducting an in-depth review the tax and transfer pricing practices of the pharmaceutical industry to make sure that the correct amount of tax . . .

Asia-Pacific

Australian legislation would impose GST on low value imports: EY→

March 1, 2017

See EY.

Asia-Pacific

Ting, Faccio, & Kadet analyze impact of Australia’s MAAL and DPT on multinational Internet businesses: SSRN→

August 17, 2016

See: SSRN.

Asia-Pacific

Australia’s tax office warns MNEs that particular transactions will be examined for tax avoidance

April 26, 2016

The Australian Taxation office (ATO) has today released four alerts, warning multinationals that specified transactions will be heavily scrutinized for tax . . .

Asia-Pacific

Final Australian inbound distributor rules detail risk of tax office scrutiny

March 20, 2019

Transfer pricing specialists, Leslie Prescott-Haar, Stefan Sunde, and Sophie Day, of TP EQuilibrium, AustralAsia LP, New Zealand, discuss final Australian guidance published March 13 addressing transfer pricing issues related to inbound distribution arrangements . . .

Asia-Pacific

Australia updates transfer pricing guidance for offshore hubs

October 16, 2018

The Australian Taxation Office (ATO) on October 11 updated its transfer pricing guidance . . .

Asia-Pacific

Amazon to block Australian customers before 10 percent GST on imported online goods kicks in: Byron Kaye/ Reuters→

June 4, 2018

   

Asia-Pacific

Australian tax office provides draft guidance on multinational anti-avoidance law 

May 2, 2018

The Australian Taxation Office (ATO) today released draft guidance discussing the meaning of the term ‘directly in connection with’ as it applies to Australia’s multinational anti-avoidance law (MAAL). The MAAL, which became . . .

Asia-Pacific

Australian draft hybrid mismatch rules hit financing arrangements, branch mismatches: Alia Lum, Liam Delahunty & Stefan Hempelmann / KPMG→

March 12, 2018
Asia-Pacific

Australia hits multinationals with large tax bills using new anti-avoidance law

April 7, 2017

Australia has assessed seven multinational corporations with tax liabilities totaling AUS $2.9 billion (~USD 2.2 billion), Treasurer Scott Morrison and Minister . . .

Asia-Pacific

Taiwan offers VAT refund to some foreign enterprises without fixed place of business

March 14, 2017

Taiwan’s taxation office announced Monday that foreign enterprises and other entities from specified countries that have no fixed place of business in Taiwan but engage in. . . 

Asia-Pacific

Australia reviewing its research and development tax incentive

September 29, 2016

The Australian government on September 28 released a draft report suggesting ways to improve the country’s research and development (R&D) tax incentive . . .

Asia-Pacific

Australian budget to lower corporate tax rate, tighten thin cap rules, sources say: Joanna Mather / Financial Review→

April 19, 2016

See: Financial Review.

Asia-Pacific

Sue Ann Khoo joins Sydney tax firm Greenwoods & Herbert Smith Freehills

April 7, 2018

Sue Ann Khoo has joined Australia’s largest specialist tax advisory firm, Greenwoods & Herbert Smith Freehills, as a . . .

Asia-Pacific

Australian hybrid mismatch bill introduced into Parliament: EY→

May 30, 2018
Asia-Pacific

Australian tax office issues 136 letters to multinationals warning of MAAL violations: Nassim Khadem / Sydney Morning Herald→

August 16, 2016

See: Sydney Morning Herald.

Asia-Pacific

Australian government introduces diverted profits tax legislation: Parliament of Australia→

February 9, 2017

See: Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017; Diverted Profits Tax Bill 2017.

MNE Tax expects to publish an analysis of this development shortly.

Asia-Pacific

Australia: country-by-country reporting exemption guidance offers relief to MNEs

October 18, 2016

The Australian Taxation Office (ATO) has issued guidance for multinational groups on how to apply for an exemption from the obligation to provide some or all of the information in required tax statements known as . . .

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 . . .

Asia-Pacific

Australian tax guidance addresses transfer pricing, debt-equity classification interaction

October 31, 2018

Australia’s debt-equity rules do not limit the operation of the transfer pricing rules, which substitute arm’s length conditions . . .

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 . . .

Australia

Australian tax agency offers multinationals guidance on tax risk management and governance

February 1, 2017

Davide Anghileri of the University of Lausanne writes about Australian Taxation Office guidance published January 27 designed to help foreign multinationals and other taxpayers understand the ATO’s views on what better tax corporate governance practices look like so companies can develop or improve their own tax governance and internal control framework . . .

Asia-Pacific

Australia steps up effort to combat corporate tax avoidance through offshore hubs, other schemes

August 10, 2016

The Australian Taxation Office (ATO) has intensified its efforts to crack down on multi­national corporation tax avoidance, launching a consultation on the aggressive use of offshore hub structures, and issuing taxpayer alerts on offshore permanent establishments . . .

Asia-Pacific

 Australia proposes R&D tax changes to encourage large company spending: Aimee Chanthadavong / InnovationsAus.com→

July 2, 2018

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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
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  • New CbC Reporting Requirements to Apply in Kenya
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    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
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  • The Evolution of Transfer Pricing in Saudi Arabia
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  • 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
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • Australian transfer pricing guidance on marketing, sales and distribution hubs released by Davide Anghileri | posted on January 17, 2017
  • 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

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