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Asia-Pacific

Americas

Japan, Peru agree in principle to tax treaty

September 7, 2019

Japan and Peru have agreed in principle to . . .

Americas

Walmart avoided US and Chinese taxes using Hong Kong shell company, Chinese joint venture taxed nowhere, former exec says: Max de Haldevang / Quartz→

September 7, 2019
Asia-Pacific

Czech finance ministry to introduce 7 percent digital tax beginning mid-2020: Reuters→

September 5, 2019
Asia-Pacific

New Malaysia tax guide addresses application of sales tax and services tax on digtial services: Royal Malaysian Customs Department→

September 4, 2019
Asia-Pacific

Singapore, UAE tax treaty amended by multilateral instrument

September 3, 2019

The Inland Revenue Authority of Singapore has announced that amendments . . .

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Leslie Prescott-Haar and Stefan Sunde at TP EQuilibrium AustralAsia discuss the Australian Tax Office’s August 28 draft guidance on applying the arm’s length debt test for thin capitalization purposes .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

Americas

US announces entry into force dates for new tax treaty protocols with Japan and Spain

September 3, 2019

The US Treasury has announced that a protocol to the US-Japan tax treaty entered . . .

Asia-Pacific

Georgia: a low-tax European country with much to offer investors

September 2, 2019

Gela Barshovi, Tax Advisor and Managing Partner at TPsolution, Tbilisi, Georgia, discusses the tax and regulatory advantages of conducting business in Georgia . . .  

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

Singapore, Turkmenistan sign comprehensive tax treaty

August 28, 2019

Singapore today signed a tax treaty with Turkmenistan, the Inland Revenue Authority . . .

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
Asia-Pacific

Singapore tax authority publishes etax guide titled “GST: Taxing imported services by way of an overseas vendor registration regime”: Inland Revenue Authority of Singapore→

August 26, 2019
Asia-Pacific

Norway disallows Telenor losses claimed upon settlement Indian subsidiary’s bank guarantees: Reuters→

August 26, 2019
Asia-Pacific

Kyocera pays ¥300 m (USD  2.8m) back taxes for not declaring income Singapore subsidiary income: Jiji Press / The Japan News→

August 26, 2019
Americas

US to raise existing tariffs on Chinese goods from 25% to 30% from Oct. 1; raise tariffs set for Sept. 1 from 10% to 15% in retaliation for Chinese tarrifs: Jacob Pramuk / CNBC→

August 26, 2019
Americas

China announces new tariffs of 5–10 percent on $75 billion worth of US goods, resumption of auto tariffs: Yum Li / CNBC→

August 23, 2019
Asia-Pacific

New Zealand government special report addresses GST on low-value imported goods: Policy and Strategy, Inland Revenue→

August 20, 2019
Asia-Pacific

China’s planned Shanghai free trade zone to feature 15 percent income tax rate for qualified business: Xinhua→

August 6, 2019
Asia-Pacific

Singapore, Ukraine tax treaty protocol signed to upgrade information sharing

August 20, 2019

Singapore and Ukraine have signed a tax treaty protocol amending their . . .

Americas

US Senate ratifies protocols to tax treaties with Japan, Switzerland, Luxembourg

July 17, 2019

The US Senate today ratified protocols to the US’s tax treaties with Japan, Switzerland, and Luxembourg. This follows the Senate ratification on . . .

Africa

Kenya, Turkey to sign tax treaty: Xinhua→

July 17, 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 . . .

Asia-Pacific

New Zealand updates tax policy work plan

August 15, 2019

The New Zealand government on August 8 updated its tax policy work plan which reflects , , ,

Asia-Pacific

MLI amendments to Singapore-Luxembourg tax treaty enter into effect

August 2, 2019

The government of Singapore has announced that amendments made to the Singapore-Luxembourg tax treaty as . . .

Armenia

Armenia, Kyrgyzstan sign tax treaty: ARMENPRESS→

August 12, 2019
Armenia

Singapore, Armenia sign tax treaty

July 8, 2019

Vietnam’s Ministry of Finance today announced . . .

Asia-Pacific

India Budget 2019: key international tax and transfer pricing developments 

July 7, 2019

Mukesh Butani and Shreyash Shah of BMR Legal Advocates discuss India Budget 2019 which includes a few proposals that will have a material impact on cross-border taxation and transfer pricing . . . 

Asia-Pacific

Singapore’s tax treaties with Netherlands and Georgia amended

July 1, 2019

The Inland Revenue Authority of Singapore has announced that amendments . . .

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

Taiwan issues guidance clarifying “beneficial ownership” for tax treaty purposes: EY→

July 1, 2019
Asia-Pacific

Israeli tax authorities issue updated transfer pricing declaration Form 1385

August 12, 2019

The Israeli tax authorities recently issued an updated Form 1385, which is a declaration regarding intercompany transactions with related parties, write Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher JH Consulting Ltd . . .

Asia-Pacific

Indonesia amendes CFC deemed dividend rules: Deloitte→

July 25, 2019
Africa

Japan, Nigeria to begin tax treaty negotiations

June 18, 2019

The Ministry of Foreign Affairs of Japan . . .

Americas

Uber generated $6.1 b Dutch tax deduction by transferring IP with increased value from a Bermuda sub to Dutch sub controlled by Singapore company: Lynnley Browning & Eric Newcomer / Bloomberg→

August 12, 2019
Asia-Pacific

Hong Kong provides guidance on transfer pricing rules and documentation requirements

July 29, 2019

Agnes Lo, Associate Professor, Lingnan University, Hong Kong and Raymond Wong, Associate Dean, City University of Hong Kong, discuss guidance issued by the Hong Kong Inland Revenue Department July 18 setting out the IRD’s views on transfer pricing, permanent establishment, and the foreign tax deduction. . . .

Asia-Pacific

Turkey proposes another tax amnesty for repatriation of foreign assets

July 17, 2019

Ramazan Biçer of Centrum Turkey discusses the Turkish government’s latest tax amnesty, proposed on July 8, which applies to the repatriation of foreign assets . . .

Asia-Pacific

China extends temporary tax break for integrated circuit and software industry: EY→

May 30, 2019
Africa

Switzerland’s Federal Council approves plan to exchange account data with 19 more country tax administration

May 30, 2019

Davide Anghileri of the University of Lausanne writes that Switzerland’s Federal Council adopted a dispatch yesterday approving the introduction of automatic exchange of financial account information with 19 more countries . . .

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
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  • New CbC Reporting Requirements to Apply in Kenya
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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

R&D Tax Credit News

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    April 20, 2022
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  • 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
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Accounting & Reporting News

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    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
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  • 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
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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
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 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

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