Asia-Pacific

Switzerland’s Federal Council approves amendments to tax treaties with New Zealand, Netherlands, Norway, Sweden

November 6, 2019

Switzerland’s Federal Council on November 6 approved four tax treaty protocols . . .

Americas

US, Singapore negotiating exchange of country-by-country reporting data

November 4, 2019

The US Treasury on October 31 announced that the US and Singapore are . . .

Asia-Pacific

Cambodia parliament ratifies tax treaty with Hong Kong: Xinhua News→

November 4, 2019

Asia-Pacific

OECD’s latest MAP review includes focus on India

October 30, 2019

The OECD on October 24 released its sixth round of Stage 1 of peer review reports on base erosion and profit shifting (BEPS) action 14, assessing India, Argentina, Chile, Colombia, Croatia, Latvia, Lithuania, and South Africa, writes Prabhakar KS of Shree Tax Chambers, Bengaluru, India . . .

Asia-Pacific

Turkey proposes 7.5 percent digital services tax on large multinationals

October 28, 2019

Ramazan Biçer a partner with Centrum, Istanbul, discusses in detail an October 23 draft digital services tax law introduced by Turkey’s Ministry of Treasury and Finance which would impose a 7.5 tax on the revenue of companies operating digital businesses Turkey . . .

Asia-Pacific

Jordan joins “Inclusive Framework on BEPS” to address taxation of multinational groups

October 28, 2019

The OECD today announced that Jordan has become . . .

Africa

OECD’s Pillar One proposal could be first step toward shift in taxing rights to destination countries: Michael Devereux / University of Oxford→

October 23, 2019

Americas

US, Armenia FATCA agreement enters into force

October 23, 2019

US Treasury has announced on its website . . .

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

Africa

Estimating reliable transfer pricing profit indicators requires use of all available data

October 23, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that the arm’s length argument of many transfer pricing reports is weak because the sample is not random and the sample size of three-year data points is too small . . .

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

Hong Kong tax agency clarifies country-by-country reporting thresholds for large MNEs

October 16, 2019

Hong Kong’s Inland Revenue Department today published new . . .

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

Africa

EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes

October 10, 2019

Davide Anghileri of the University of Lausanne, Switzerland, resolutions relating to taxation adopted by the of the EU Council today . . .

American Samoa

Netherlands government publishes revised draft list of low tax jurisdictions

October 8, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s October 7 release of a draft list of low tax jurisdictions which makes four changes from the previous list. . . .

Africa

EU Code of Conduct Group proposes changes to tax blacklist for seven countries including Switzerland, UAE, Mauritius

October 8, 2019

Davide Anghileri of the University of Lausanne, Switzerland, discusses October 4 EU Code of Conduct Group (Business Taxation) recommendations for amendments to the EU list of non-cooperative tax jurisdictions . . .

Asia-Pacific

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

October 7, 2019

Americas

Return on assets (ROA) is an unreliable profit indicator

October 2, 2019

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that selection of “return on assets” as a profit indicator in transfer pricing can lead to intractable controversy because the term is ill-defined whereas operating profit margin and operating profit markup are more reliable . . .

Africa

Japan, Morocco agree to terms of new tax treaty

October 1, 2019

The Ministry of Foreign Affairs of Japan today announced that . . .

Asia-Pacific

Turkey: new tax audit wave focuses on nonresident digital companies

October 1, 2019

Ramazan Biçer, a partner with Centrum, Istanbul, discusses a new wave of tax audits being undertaken in Turkey scrutinizing the taxation of nonresident taxpayers engaged in the digital economy . . .

Asia-Pacific

Australian tax office advises on transfer pricing for offshore drilling

September 27, 2019

The Australian Taxation Office (ATO) on . . .

Asia-Pacific

Hong Kong signs tax treaty with Estonia

September 26, 2019

The Hong Kong government today announced that Hong Kong and Estonia have signed a . . .

Asia-Pacific

Indian court rules Hitachi Singapore’s liaison office is a permanent establishment

September 26, 2019

Chartered Accountants Deepak Manoharan and Nathansha Dilip discuss the Hitachi case, a landmark ruling where the Delhi bench of the Income Tax Appellate Tribunal concludes that a liaison office could be treated as a permanent establishment of a foreign entity in India . . .

Asia-Pacific

Japan, Uzbekistan agreed in principle to tax treaty

September 24, 2019

The governments of Japan and Uzbekistan have . . .

Asia-Pacific

India fires bazooka to lift economy, slashing corporate tax rates and enacting other tax relief

September 23, 2019

Rajesh Gandhi and Gaurav Chandak of Deloitte Haskins & Sells LLP, Mumbai, discuss the Indian government’s surprise announcement on Friday of a significant reduction in the corporate tax rates which became effective immediately . . .

Asia-Pacific

Philippines issues transfer pricing audit guidelines: EY→

September 19, 2019

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Europe

New Zealand, Guernsey sign tax treaty protocol

September 18, 2019

The governments of New Zealand and Guernsey have signed protocol to their tax information . . .

Americas

Japan, Uruguay sign tax treaty

September 18, 2019

The governments of Japan and Uruguay on September 13 signed their . . .

Asia-Pacific

India specifies transfer pricing arm’s length tolerance range

September 17, 2019

Gaurav Jain, a chartered accountant, and Priya Bhutani discuss Indian guidance released September 13 addressing the transfer pricing arm’s length tolerance range for wholesale trading and other activities . . .

Asia-Pacific

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

September 17, 2019

Asia-Pacific

Vietnam to use legal, economic, technological means to collect tax from cross border services, official says: CustomsNews→

September 16, 2019

Armenia

Armenia approves ratification of Armenia-Denmark double tax treaty: ARMENPRESS→

September 12, 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

Hong Kong tax authority updates penalty policies for international tax

September 11, 2019

The Hong Kong Inland Revenue Department announced September 4 that it has updated its webpage on penalty policies related to international tax . . .

Asia-Pacific

Japan, Uzbekistan commence tax treaty negotiations

September 9, 2019

The governments of Japan and Uzbekistan begun tax treaty negotiations, the . . .

Asia-Pacific

Hong Kong government website updated to specify transfer pricing documentation requirements: Inland Revenue Department→

September 9, 2019

Asia-Pacific

Hong Kong government publishes revisions to practice note on deduction for foreign losses: Inland Revenue Department of Hong Kong→

September 7, 2019

Asia-Pacific

Indonesia government to introduce bill making foreign digital firms liable for 10 percent VAT, cutting corporate rate: Reuters→

September 7, 2019

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

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin