Officials representing 68 countries and jurisdictions on June 7 signed a multilateral instrument to amend their existing tax treaties, adding provisions designed to curtail multinational tax avoidance and strengthen tax dispute resolution . . .
Australia’s Full Federal Court today dismissed Chevron’s appeal in a transfer pricing case involving intercompany loans, handing the Australian Taxation Office (ATO) a key victory. By unanimous judgment, the full bench . . .
Tax professional Ninja-Antonia Reggelin discusses a German parliamentary hearing, held Wednesday, where tax experts provided their views on a controversial proposal to deny tax deductions for some royalty payments made by multinationals to related companies. . .
Julian Feiner of Dentons, London, discusses the tax proposals in the UK budget, delivered today, which include proposed revisions to interest deductibility, loss relief, and hybrid mismatch rules . . .
The European Council on February 7 released the Maltese Presidency’s work plan regarding tax measures to prevent base erosion and profit shifting by multinationals, notes Davide Anghileri of the University of Lausanne . . .
Daniel Garabedian and Steven Peeters, of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss a Belgian law passed last week that modifies the tax incentives for multinational enterprises that derive income from intellectual property rights . . .
Masao Yoshimura, Associate Professor of Tax Law at the Graduate School of International Corporate Strategy, Hitotsubashi University, Tokyo, writes about a proposal to revise Japan’s controlled foreign company law, released December 8 by Japan’s ruling coalition . . .
The Australian Taxation Office (ATO) is warning multinationals that it will contest a tax planning maneuver designed to thwart Australia’s new Multinational Anti Avoidance Law (MAAL) as well as ’round robin’ type intragroup financing arrangements that generate . . .
G20 leaders during their summit in Hangzhou, China, held September 4–5 endorsed a proposal setting out objective criteria to be used to identify whether countries are sufficiently tax . . .
The European Commission on June 7 published the non-confidential version of its decision to open a State aid investigation into whether a tax ruling granted by Luxembourg to McDonald’s may have granted . . .
The OECD on May 31 issued a request for the public to assist with technical questions associated with the development of a multilateral instrument to be used by countries that wish to implement tax measures . . .
The EU Commission has issued a paper outlining its position on when a Member State’s laws and practices run afoul of EU restrictions on State aid, including when national tax laws, tax rulings, and tax settlements . . .
A new draft chapter on intragroup services for the United Nations Practical Manual on Transfer Pricing for Developing Countries (the UN transfer pricing manual), publicly released last week, differs from OECD guidance on the topic in a few areas, according to . . .
Francisco Sepúlveda of RGS Abogados discusses the Chilean government’s proposed tax reform plan, presented August 23, which would reestablish full corporate tax integration, introduce new permanent establishment definitions, weaken the GAAR, enhance deductible business expenses, and impose a new withholding tax on digital services to be collected by credit card companies, among other measures . . .
Michael Bernard and Nancy Manzano of Vertex Inc. discuss today’s US Supreme Court’s decision in Wayfair, which overturned the 1992 Quill v. North Dakota ruling and changed the physical presence requirements for sales and use tax collection for online sellers, out-of-state merchants, and global companies selling to US-based customers . . .
Zara Ritchie and Natalya Marenina of BDO take a look back at the most significant Australian international tax developments of 2017 — including the new focus on significant global entities, transfer pricing documentation, diverted profits tax, and cross-boarder financing — and consider what 2018 is likely to bring . . .
JP Canavan discusses newly released draft instructions to US Form 8975, which include information on early country-by-country reporting for US-parented MNEs and on how to report ‘stateless’ constituent entities . . . . . .
Switzerland and the UK will terminate their 2013 withholding tax agreement as of January 1, 2017, under a deal struck . . .
EU finance ministers at a meeting of the ECOFIN today failed to reach agreement on the EU Commission’s proposed anti-tax avoidance directive, though officials remained optimistic that a compromise agreement can . . .
The Australian government on May 3 released its 2016–17 budget, announcing several measures to crack down on multinational tax avoidance, including a tough new diverted profits tax (DPT), anti-hybrid and transfer pricing rules patterned after . . .
David W. Powell and Kevin Walsh of the Groom Law Group analyze recently issued draft revisions to the OECD Model Tax Convention concerning the tax residence of pension funds, and compare the OECD provisions to those in the updated US model tax treaty. . . .
There appears to be no slow down in OECD activity even though work on the base erosion profit shifting (BEPS) deliverables is complete, Robert Stack, Treasury Deputy Assistant Secretary . . .
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
