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Australia proposes anti-hybrid law to combat multinational tax avoidance, announces plans for “targeted integrity rule”
The Australian government on November 24 released a draft law and explanatory materials implementing hybrid mismatch rules to combat multinational firm tax avoidance. The Australian government is also developing a “targeted integrity rule” to prevent circumvention of the hybrid mismatch rules as well as branch mismatch rules to further clamp down on MNE tax . . .
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Featured News
Indian secondary adjustments for transfer pricing: what you need to know about the new rules
India transfer pricing and tax litigator Ajit Jain discusses new transfer pricing rules providing for secondary adjustments . . .
Asia-Pacific
Australian diverted profits tax legislation introduced
Julian Feiner of Dentons, London, discusses proposed Australian legislation, introduced into Parliament February 9, that would implement a diverted profits tax, comparing the draft to the UK DPT . . .
Asia-Pacific
Indian circular clarifies coming GAAR: Central Board of Direct Taxes→
See: Central Board of Direct Taxes. *The circular will be analyzed in a forthcoming MNE Tax article.
Asia-Pacific
Protocol to Singapore-Russia tax treaty enters into force
A protocol amending the 2002 Singapore-Russia tax treaty entered into force on November 25, the Inland Revenue Authority of Singapore has . . .
Asia-Pacific
Asia-Pacific
Africa
Ireland says tax treaty with Ethiopia entered into force, updates status of treaties with Ghana, Oman, South Africa
Irish Revenue has announced that a new double taxation agreement with Ethiopia entered into force on August 12. The treaty, signed November 3, 2014, will . . .
Africa
India-Mauritius tax treaty re-negotiated: what it means for international business
Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Shipra Padhi, a senior international tax specialist based in the firm’s Mumbai office, discuss how the taxation of foreign investment in India will change as a result of the renegotiation of the India-Mauritius tax treaty . . . .
Asia-Pacific
New Zealand details new law extending goods and services tax to cross-border services
New Zealand’s Inland Revenue Department on May 17 published a special report providing information on a new law that will impose the goods and services tax (GST). . .
Asia-Pacific
Japan and Belgium agree to terms of new tax treaty
Japan and Belgium have agreed to the terms of new tax treaty, Japan’s Ministry of Finance announced . . .
Americas
US and India to begin negotiating bilateral APAs, 100 transfer pricing disputes resolved
Reassured by the successful settlement of numerous long-pending transfer pricing disputes, the US competent authority has agreed to soon begin negotiating bilateral advance . . .
Update (2/1/2016): US confirms it will accept Indian bilateral APA applications: The US IRS, on February 1, confirmed that, beginning February 16, the US competent authority will accept applications . . .
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India hits Hutchison with Rs 32,320 crore (USD 4.8 billion) tax bill in ongoing Vodafone dispute: The Economic Times→
Source: Vodafone: Income Tax department seeks Rs 32,320 crore from Hutchison over Vodafone deal – The Economic Times
Asia-Pacific
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Indian POEM – not so poetic! An analysis of India’s new place of effective management rules
Ashish Sodhani and Ameya Mithe of Nishith Desai Associates provide a comprehensive analysis of India’s new guidelines for determining a foreign company’s place of effective management . . .
Asia-Pacific
Asia-Pacific
Australian guidance defines “Australian consumer” for cross-border VAT rules
The Australian Taxation Office, on December 22, published a draft goods and services ruling (GSTR 2016/D1) discussing the meaning of “Australian Consumer” for purposes of rules that . . .
Americas
Macao and US sign Model 2 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Macao and the US have signed a Model 2 intergovernmental . . .
Africa
BRICS: tax policies should enhance growth, address BEPS
BRICS leaders, following their summit held October 15–16, called for tax policies that promote inclusive growth and expressed support for the implementation of the OECD/G20 base erosion profit shifting . . .
Asia-Pacific
Asia-Pacific
Kuwait signs tax transparency agreement
The OECD has announced that Kuwait has signed the CRS Multilateral Competent Authority Agreement, a step required to put into place automatic exchange of financial account information with . . .
