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EU Council approves new cross-border tax dispute resolution plan
As expected, the ECOFIN Council today approved a directive establishing a new system for resolving double taxation disputes between EU member states. The new directive on tax dispute resolution follows an agreement reached by EU nations on May 23. It was approved without discussion. Member states will have until June . . .
Asia-Pacific
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Europe
Swiss panel offers revised corporate tax reform proposal
A steering group charged with preparing a new plan for Swiss corporate tax reform has presented its objectives and recommendations, called Tax Proposal 17, writes
Davide Anghileri of the University of Lausanne . . .
Asia-Pacific
India confirms intent to sign BEPS multilateral instrument curbing tax avoidance
Mansi Seth and Afaan Arshad of Nishith Desai Associates discuss today’s announcement that the Indian Union Cabinet has approved India’s signing of the multilateral instrument (MLI) to implement the tax treaty measures in the OECD/G20 base erosion profit shifting (BEPS) action plan . . .
Americas
Brazil’s country-by-country reporting obligation
Francisco Lisboa Moreira, an attorney with Castro, Barros, Sobral, Gomes, discusses Brazil’s country-by-country reporting requirement for large multinationals, identifying unresolved questions associated with the new rules . . .
Africa
South Africa Budget includes dividend withholding tax increase
Dr. E. Brincker of Cliffe Dekker Hofmeyr, Johannesburg, discusses international tax proposals in the South Africa budget, delivered February 22, that will affect multinational corporations . . .
Europe
German limit on tax deduction for related-party royalty payments approved by cabinet
The German cabinet has approved a draft law limiting tax deductions for cross-border royalty payments to related parties, writes Berlin-based practitioner, Ninja-Antonia Reggelin . . .
Asia-Pacific
Australian transfer pricing guidance on marketing, sales and distribution hubs released
Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO’s approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .
Featured News
OECD officials outline international tax initiatives, country-by-country reporting guidance released
OECD officials, during a December 5 webcast, discussed OECD international tax work, including just-released guidance implementing country-by-country reporting standards, the G20’s tax agenda, the BEPS multilateral instrument, OECD drafts on profit splits . . .
Europe
Swiss bank can’t reveal client’s account administrator or referring law firm to US, court rules
Switzerland’s Federal Supreme Court, in a decision made public yesterday, has concluded that a bank in the Swiss Canton of Ticino is prohibited from divulging the names of lawyers and a law firm associated with the bank’s US clients to the US IRS and Department of Justice, writes guest author Davide Anghileri . . .
Americas
Canada releases draft tax legislation to implement 2016 budget proposals
Kabir Jamal, an attorney with Goodmans LLP, Toronto, reports that the Canadian government has just released for consultation draft tax proposals to implement measures in Budget 2016 . . .
Europe
Irish tax authority introduces formal bilateral advance pricing agreement program
Irish Revenue has today released guidelines establishing a formal bilateral advance pricing agreement (APA) program to provide certainty for multinational corporation transfer pricing . . .
Asia-Pacific
Australian bill imposes GST on digital products and other intangibles supplied by nonresidents
Australia’s Treasurer on February 10 introduced into Parliament a bill that would impose the 10 percent goods and services tax (GST) to all supplies by nonresidents to Australian consumers except for supplies of goods and real property. A second measure . . .
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OECD report reveals disagreement on taxation of digital firms
A highly anticipated OECD interim report, published today, reveals that there is still no consensus among countries on whether changes should be made to international tax rules that apply to multinational digital firms. Countries did agree to study international tax concepts to see if improvements can be made, though. Also, while the report states that there is no consensus on short-term interim measures to tax the digital economy either, countries . . .
Americas
Experts consider next round of US international tax changes, BEAT as leverage in EU tax negotiations
With the ink still drying on a sweeping reform of the US international tax system, academics, economists, government officials, and tax practitioners gathered in Washington at the February 2 IIEL & ITPF tax conference to offer suggestions on how to replace or revise the new law and discussed how to the BEAT might be used as leverage in tax negotiations with the EU . . .
Asia-Pacific
Americas
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Africa
Twenty nations’ tax laws may aid multinational profit shifting, OECD report says
Twenty countries have tax laws that may be considered harmful preferential regimes, facilitating tax avoidance by multinationals and reducing the tax base of other countries, an OECD report released Monday revealed. The review, conducted by the OECD Forum on Harmful Tax Practices (FHTP), assessed countries’ tax laws against . . . .
Featured News
UN committee weighing major updates to model tax treaty, other guidance
The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . .
Americas
IRS announces issue-based campaign to increase tax compliance of large companies, international business
The US IRS has announced that it has selected 13 tax and transfer pricing topics that it will focus on in an issue-based campaign to increase the tax compliance of large and/or international businesses. In a January 31 announcement, the IRS’ Large Business and International division (LB&I) said it will . . .
Asia-Pacific
Report details India’s plan for equalization levy to tax digital economy
The Indian government on Monday released a high level report that appears to have influenced Finance Minister Arun Jaitley’s budget proposal for a 6 percent equalization levy on e-commerce . . .
Europe
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