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Americas

Corporate veil dropping: British crown dependencies make beneficial ownership registers public, US takes baby steps

June 24, 2019

Virginia La Torre Jeker, J.D., a US tax practitioner located in Dubai, discusses June 19 announcements of Jersey, Guernsey, and the Isle of Man about plans to make beneficial ownership registers for legal entities public and US legislation proposed June 11 in this area . . .

Europe

Netherlands proposes four options for revising corporate tax group regime

June 20, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a June 17 consultation launched by the Dutch State Secretary of Finance outlining possible approaches for a new corporate tax group regime in the Netherlands . . .

Asia-Pacific

India ratifies multilateral tax convention

June 13, 2019

Prabhakar KS of Shree Tax Chambers, Bengaluru, India, discusses the June 12 ratification by India of the Multilateral Convention to implement the Tax Treaty related measures to prevent Base Erosion and Profit Shifting (MLI) almost 2 years after signing it . . .

129-country coalition agrees to work plan to develop new international tax and transfer pricing rules

May 28, 2019

The BEPS Inclusive Framework today agreed to a work plan to develop international tax and transfer pricing rules that address the problems . . .

Africa

Mauritius amends country-by-country reporting rules to add penalties for noncompliance

May 27, 2019

Akshar Maherally, Managing Director of WTS Tax Consulting (Mauritius) Ltd, Mauritius, discusses new rules, published May 4, that impose penalties on multinationals that do not comply with country-by-country reporting requirements . . .

Europe

German cabinet passes R&D tax incentive

May 23, 2019

German practitioner Ninja-Antonia Reggelin notes that the German cabinet passed a bill introducing a new tax incentive for research and development (R&D) on Wednesday . . .

Africa

Journalists publish details of 200+ companies using offshore law firm, conclude Mauritius promotes tax avoidance

July 23, 2019

Data on more than 200 companies that engaged the Mauritius office of Conyers Dill & Pearman were published on the internet today by the . . .

Europe

Netherlands announces tax policy agenda for 2019

June 12, 2019

Jian-Cheng Kua and Rhys Bane of DLA Piper, Netherlands, discuss the Dutch government’s May 29 announcement of priorities and timelines in the area tax policy . . .

Americas

Peru issues new tax guidance on indirect transfers

June 7, 2019

Carlos Vargas Alencastre and Franz Salazar Anccasi of TPC Group Peru, discuss guidance issued June 4 by Peru’s tax administration on the indirect transfer rules, which levy tax on the transfer of shares in a non-Peruvian company that directly or indirectly owns shares in a Peruvian company . . .

Europe

Swiss corporate tax reform approved by popular referendum

May 19, 2019

Davide Anghileri of the University of Lausanne writes about Switzerland’s corporate tax reform, approved by a popular referendum on Sunday, May 19 . . .

Americas

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

July 23, 2019

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved. . .

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Europe

French DST passed by Parliament clarifies location of users

July 15, 2019

Pascal Luquet of Grant Thornton Société d’Avocats discusses the details of the final version of the French digital services tax, adopted by French Parliament on July 11 . . .

Americas

Argentina offers new tax incentives for high tech businesses

June 17, 2019

Sandra Diaz a partner at Basa Firma, writes about Argentina tax incentives, enacted June 6, designed to encourage high technology businesses to locate there . . .

Americas

First Look: US IRS issues final GILTI regulations, proposed DRD regs

June 16, 2019

The US IRS on June 14 released final and proposed regulations on the global intangible low-taxed income (GILTI) regime of section 951A, a key part of the 2018 Tax Cuts and Jobs Act. . .

Asia-Pacific

UAE country-by-country reporting rules published

July 30, 2019

Saumitra R. Bhagwat and George German of Deloitte Middle East discuss new UAE Ministry of Finance transfer pricing guidance which sets out country-by-country reporting compliance obligations for multinational corporation groups. . .

Denmark

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

July 23, 2019

The Danish tax administration on July 12 published a decree specifying new transfer pricing documentation rules and allowing some transfer pricing cases to be reopened where discretionary assessments were made, write Johnny Bøgebjerg and Henrik Lund of KPMG Acor Tax, Denmark. . . .

Asia-Pacific

China APA report shows government’s continued reliance on transactional net margin method

June 18, 2019

Agnes Lo, Associate Professor, Lingnan University, Hong Kong, and Raymond Wong, Associate Dean at City University of Hong Kong, discuss China’s State Taxation Administration’s most recent report on its advance pricing arrangement program . . .

Asia-Pacific

New Zealand digital services tax update

June 11, 2019

Leslie Prescott-Haar, Stefan Sunde and Sophie Day of TP Equilibrium AustralAsia discuss a consultation launched by New Zealand Inland Revenue June 4 proposing a 3 percent digital services tax . . .

Digital Economy

G20 finance ministers endorse Inclusive Framework’s work plan for international tax reboot

June 9, 2019

G20 finance ministers and central bank governors at their June 8–9 meeting in Tsukuba, Japan, endorsed a work plan developed by a 129-country coalition called the “Inclusive Framework on BEPS” which provides . . .

Americas

New Peru transfer pricing guidance addresses related-party share transfers

May 23, 2019

Carlos Vargas Alencastre and Franz Salazar Anccasi of TPC Group, Lima, Peru, discuss new Peruvian transfer pricing guidance released May 16 . . .

Europe

Takeaways from Italy’s new transfer pricing country profile

June 28, 2019

Gian Luca Nieddu of Hager & Partners, Milan area, Italy, discusses the latest version of Italy’s transfer pricing country profile, prepared by Italian Central Revenue, published on the OECD webpage a few days ago, which reflects the agency’s latest views on transfer pricing enforcement . . .

Africa

Mauritius to add new tax incentives, changes to partial exemption regime

June 12, 2019

Johanne Hague, Senior Partner, Juristconsult Chambers, Ebene, Mauritius, discusses tax changes in the Mauritius budget for 2019—2020, delivered June 10 . . .

Americas

First look: Altera reversed on appeal, US cost sharing regs are valid

June 9, 2019

The United States Court of Appeals for the Ninth Circuit on Friday reversed the Tax Court’s decision in Altera, finding that . . .

Africa

Zimbabwe introduces digital economy tax, transfer pricing filing requirement

June 2, 2019

Walker Nyachowe, Founder & Managing Director, of Walker Consulting Services, discusses Zimbabwe’s 2019 budget which introduces a new tax on the digital economy and new transfer pricing return filing requirements . . .

Belgium

Belgium transfer pricing reporting burdens reduced through legislation

June 2, 2019

Geoffroy Galéa of Laga (Deloitte Legal) and Laura Deroy and Florence Siccard of Deloitte, Belgium, discuss new legislation introduced in Belgium on May 15 that decreases in the compliance burden related to the transfer pricing reporting obligations of multinational groups . . .

Europe

Google doesn’t owe French tax on sales to advertisers, court rules

May 23, 2019

Pascal Luquet, Mickaël Duquenne, and Paul Bufort of Grant Thornton Société d’Avocats, Neuilly-Sur-Seine, France, discuss Google’s latest court win in France where the Paris administrative court of appeal confirmed that Google Ireland had no permanent establishment in France and that Google was not taxable in France on Google AdWords sales to French advertisers those years . . .

Americas

Agreement reached on OECD transfer pricing guidelines for financial transactions, official says

June 8, 2019

Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .

Asia-Pacific

India defers GAAR reporting provisions

May 14, 2019

Prabhakar K S of Shree Tax Chambers writes that the Indian government, on May 14, for the second time deferred reporting requirements for general anti-avoidance rule (GAAR) compliance . . .

Europe

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

July 22, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a July 12 Netherlands government proposal requiring intermediaries and, in some cases, taxpayers, to report cross-border arrangements that meet certain hallmarks to the tax authorities. . . .

Africa

Kenya budget proposes new tax on digital economy, capital gains tax hike, enhanced tax incentives

June 26, 2019

George Maina an Associate partner at Rödl & Partner Limited, Nairobi, discusses the Kenyan budget statement for the fiscal year 2019—2020, announced June 13, which includes tax changes of interest to multinationals . . .

Americas

Argentina modifies transfer pricing regime

May 29, 2019

Sandra Diaz, a partner with Basa Firma, discusses changes to Argentina’s transfer pricing requirements published on May 27 . . .

Asia-Pacific

New Zealand’s revised transfer pricing regime

May 13, 2019

Leslie Prescott-Haar, Stefan Sunde, and Sophie Day of TP EQuilibrium | AustralAsia LP, discuss final international tax and transfer pricing guidance published by the New Zealand Inland Revenue April 29 . . .

Europe

Italy amends patent box regime, adopts other tax reforms

May 9, 2019

Davide Anghileri of the University of Lausanne discusses a new package of Italian tax measures which include amendments to Italy’s patent box regime and an asset basis step-up on certain mergers, division, or contributions . . .

Europe

EU court rules on deductibility of losses of sub-subsidiary, losses transferred through merger

June 24, 2019

Davide Anghileri of the University of Lausanne discusses two ECJ decisions released June 19 addressing when EU States are required by EU law to allow a parent company to deduct in Sweden final losses of a group member; one case involved losses of a sub-subsidiary located in Spain and the other of a Germany subsidiary later merged into its Swedish parent . . .

French court reaches surprising conclusions on cost plus transfer pricing method

June 6, 2019

Terence Wilhelm of Cara Avocats, France, discusses a French case, Labs France, where the court addressed the treatment of taxes for purposes of the cost plus transfer pricing method . . .

OECD publishes work plan for sweeping international tax reform

May 31, 2019

As expected, the OECD today published a work plan setting out a process for reaching global consensus on revised rules for taxing multinationals. This key document had been agreed to by the 129-country . . .

Americas

Peru clarifies general anti-avoidance rule for cross-border transactions

May 8, 2019

Franz Salazar Anccasi of TPC Group, Peru, discusses important changes to Peru’s general anti-avoidance rule published on May 6 . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

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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