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Asia-Pacific

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 . . .

Asia-Pacific

India tax authority releases welcome guidance on appropriate use of country-by-country reports

August 9, 2018

Suchint Majmudar, Hussain Sunel, and Praneeth Narahari of Deloitte Touche Tohmatsu India LLP discuss new Indian guidance addressing the appropriate use of MNE country-by-country reports by government personnel . . . .

Asia-Pacific

New Hong Kong, Finland tax treaty reduces withholding tax, benefits airlines and shipping

May 25, 2018

Hong Kong and Finland’s governments signed a comprehensive tax treaty on May 24. The agreement, which . . .

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 . . .

Asia-Pacific

Andersen Global collaborating with UAE tax firm, GN Global Consulting 

January 23, 2018

Andersen Global on January 16 announced it has entered into a collaboration agreement with one of the oldest independent tax firms in Dubai . . .

Asia-Pacific

India: multinationals faced shifting tax landscape in 2017

January 2, 2018

Mansi Seth and Shashwat Sharma of Nishith Desai Associates discuss 2017 changes to India’s tax and transfer pricing laws that will have the greatest impact on multinationals, including GAAR, PE, secondary adjustments, and POEM changes . . . 

Asia-Pacific

New Cambodian transfer pricing regulations cover documentation, audits: Duff & Phelps→ 

October 30, 2017
Asia-Pacific

Taiwan tax reform proposal would increase corporate, dividend withholding tax rates: Deloitte→

September 7, 2017
Asia-Pacific

Israel: transfer pricing changes proposed: PWC→

February 16, 2017

See: PWC.

No Picture
Americas

Switzerland weighs expansion of automatic exchange of tax information to 20 more countries

February 2, 2017

Davide Anghileri of the University of Lausanne discusses Switzerland’s decision to launch a consultation on automatic exchange of information with 20 more countries . . .

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

Japan and Lavia sign first tax treaty, text available

January 18, 2017

The governments of Japan and Latvia today signed a their first tax treaty, Japan’s Ministry of Finance has announced. The agreement, signed in Tokyo, would exempt royalties . . .

Asia-Pacific

Japan, Lithuania initial draft tax treaty

January 6, 2017

Japan and Lithuania have agreed in principle to a tax treaty, Japan’s Ministry of Finance . . .

Americas

Israeli High Court concludes law implementing FATCA is valid: Dov Benovadia / Hamodia→

September 13, 2016

See: Hamodia.

Asia-Pacific

Israel proposes significant tax breaks to attract multinational corporation investment

August 16, 2016

Professor Rifat Azam discusses a draft Israeli proposal that offers big tax incentives to large multinationals that invest in Israel, particularity IP and knowledge-based investments . . . 

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

China raises taxes on cross-border e-commerce retail imports from April 8: DLA Piper→

April 8, 2016

See: DLA Piper. More: Dezan Shira & Associates.

Asia-Pacific

Hong Kong tax bill introduces temporary tax cuts

March 4, 2016

The Hong Kong government on March 4 published Inland Revenue (Amendment) (No. 2) Bill 2016, to implement the concessionary revenue measures proposed in the . . .

Asia-Pacific

Hong Kong, Russia tax treaty signed

January 19, 2016

Hong Kong and Russia signed a new tax treaty on January 19, Hong Kong’s Inland Revenue Department . . .

Asia-Pacific

Hong Kong, Finland tax treaty enters into force

January 7, 2019

A comprehensive tax treaty between Hong Kong and Finland entered into force . . .

Asia-Pacific

Denmark-Japan double tax treaty enters into force 

January 3, 2019

Michael Vorndran, a principal with Nord Advisory AS, Oslo, Norway, notes that a new tax treaty between Denmark and Japan has entered into force . . .

Americas

Bermuda, Curaçao, Hong Kong,  Liechtenstein update plans to exchange country-by-country reports on MNEs

September 13, 2018

The OECD today reported that Bermuda, Curaçao, Hong Kong, and Liechtenstein have announced new bilateral exchange relationships with other . . .

Africa

OECD publishes transfer pricing profiles for Costa Rica, Greece, South Korea, Panama, Seychelles, South Africa, Turkey, Singapore

September 7, 2018

The OECD today announced the release of new transfer pricing . . .

Asia-Pacific

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

July 2, 2018
Asia-Pacific

Indonesia offers 100 percent corporate income tax holiday for taxpayers investing in certain industries: EY→

April 12, 2018
Asia-Pacific

Japan enacts tax bill changing PE definition, restricting R&D credit: EY→

April 9, 2018
Asia-Pacific

Japan, Croatia to begin tax treaty negotiations

March 7, 2018

Japan’s Ministry of Finance today announced that it will enter into tax treaty . . .

Asia-Pacific

Google to stop funneling New Zealand profits through low-tax Singapore: Matt Nippert / NZ Herald→

February 23, 2018
No Picture
Africa

EU updates list of non-cooperative jurisdictions in taxation matters

January 23, 2018

Today the Council of the European Union removed Barbados, Grenada, the Republic of Korea, Macao SAR, Mongolia, Panama, Tunisia and the United Arab Emirates from the EU list of non-cooperative jurisdictions in taxation matters, writes Davide Anghileri of the University of Lausanne, Switzerland . . . .

Asia-Pacific

Hong Kong bill would revise multinational firm tax and transfer pricing rules

January 2, 2018

The Hong Kong government on December 29 published a tax bill in its official gazette, proposing to introduce a transfer pricing regime and establish an advance pricing arrangement program. Inland Revenue (Amendment) (No. 6) Bill 2017 also adopts rules requiring transfer pricing documentation, including country-by-country reporting . . .

Asia-Pacific

Australia extends tax avoidance probe to ExxonMobil challenging zero corporate tax paid, related-party loans: Peter Hill / Bloomberg BNA→

December 7, 2017
Asia-Pacific

Payments by Google India were royalties subject to withholding tax, tribunal rules

October 30, 2017

Mansi Seth and Joachim Saldanha of Nishith Desai Associates discuss an October 24 Indian tribunal decision which held that payments made by Google India to Google Ireland for marketing and distribution of online ad space through the Google’s AdWords program were royalty payments subject to withholding tax . . .

Americas

Illinois bill would forbid state contracts with expatriated residents of 38 ‘tax havens’ including Luxembourg: Brendan Bakala / Illinois Policy→

April 10, 2017
Asia-Pacific

Japan, Russia negotiate tax treaty

March 27, 2017

Japan and Russia have begun negotiations to amend their tax treaty, Japan’s Ministry of Finance has announced. The . . .

Asia-Pacific

Hong Kong, Pakistan sign tax treaty

February 21, 2017

Hong Kong and Pakistan signed a tax treaty on February 17, the Hong Kong government has announced. This is the 37th tax treaty signed by . . .

Asia-Pacific

India issues tax guidance on MNE place of effective management: Central Board of Direct Taxes→

January 27, 2017

See: Central Board of Direct Taxes.

*This guidance will be analyzed in a forthcoming MNE Tax article.  

Asia-Pacific

Chevron case reveals failure of OECD rules to aid pricing of intragroup loans, Australian professors say: Richard J. Vann, Graeme S. Cooper / SSRN→

August 23, 2016

See: SSRN.

Armenia

Germany, Armenia sign tax treaty: Akholi News→

June 30, 2016

See:  Akholi News.

Posts navigation

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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
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Latest

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Recent Comments

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  • 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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Accounting & Reporting News

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Transfer Pricing News

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US tax focus

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