Mohit Agarwal, a Tax Director at PwC India, discusses important guidance issued by the Indian government on June 22 relating to computation of tax liability, applicable tax rates, and related compliance once a foreign company’s ‘place of effective management’ (PoEM), and thus the company’s tax residence, is determined to be in India . . .
Countries working on an OECD-led effort to create uniform transfer pricing rules for related-party financial transactions are having a difficult time reaching agreement; thus, a long-awaited OECD draft on the matter, slated for release this summer, will highlight country disagreements rather than propose new . .
The OECD expects to soon release an important update to its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, tax officials said during a June 26 webinar. Officials also discussed the OECD’s coming release of a discussion draft . . .
The EU Commission today published a non-confidential version of its decision concluding that an advance pricing agreement (APA) granted to a Starbucks subsidiary by the Netherlands is illegal State aid and ordering recovery of the . . .
Joel Cooper of DLA Piper, London, follows up his report from last week, analyzing the newly-released text of WCO guidance on the use of a transfer pricing studies employing the TNMM method to prove customs values. . .
The EU Code of Conduct Group will focus on addressing non-cooperative, non-EU, tax jurisdictions; monitoring EU implementation of the modified nexus approach for patent boxes; and assessing EU countries’ standstill and rollback of harmful tax measures, according to its work plan, released February 15, writes Davide Anghileri, University of Lausanne . . .
Finance ministers from Italy, Germany, France, the UK, and Spain have written to US Treasury Secretary Steven Mnuchin warning that provisions in the US tax reform bill contravene the US’s tax treaty and World Trade Organizations (WTO) obligations as well as international agreements reached under the OECD/G20 base erosion profit shifting (BEPS) plan. The ministers – Italy’s Pier Carlo Padoan, Germany’s . . .
Davide Anghileri of the University of Lausanne, an MNE Tax contributing editor, discusses a meeting of the UN Committee of Experts on International Cooperation in Tax Matters, held in Geneva 17– 20 October, where new committee co-chairs were elected and subcommittee assignments were set, including assignments for a new subcommittee on the digitization of the economy . . .
The European Court of Justice (ECJ), in a ruling released September 12, has concluded that the ECJ has jurisdiction to resolve a dispute between Member States which relates to the subject matter of the Treaties of the European Union if the dispute is submitted under a special agreement between the parties, writes Davide Anghileri of the University of Lausanne. . .
JP Canavan discusses a proposed law, advanced by Australian government on February 16, which would overhaul the goods and services tax (GST) regime in relation to the importation of low value goods by consumers. . .
The New Zealand government on March 3 released a slew of tax proposals in three consultation documents all aimed at preventing tax avoidance . . .
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
On 17 November, the EU Code of Conduct Group published a report on the work done by a subgroup during the Slovak Presidency on the clarification of the third and fourth criteria (i.e., substance and internationally accepted principles) of . . .
Wiebe Dijkstra and Peter Spijker of De Brauw Blackstone Westbroek, Amsterdam, discuss tax changes in the Netherlands government’s 2017 Budget that affect multinational businesses, international investors, and investment funds . . .
Steptoe & Johnson LLP partner, Amanda Varma, discusses the recent announcement that the US and Ireland are renegotiating their tax treaty, and identifies provisions in the existing US-Ireland tax treaty that the US will likely try to modify . . .
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a Dutch Court of Appeal decision which requires the Netherlands to extend its fiscal unity-regime to Dutch companies that have foreign parents resident in Israel or resident in countries that have a tax treaty with a nondiscrimination clause similar to that in the Netherlands/Israel tax treaty. . .
Stefano Mariani, a lawyer and lecturer at Hong Kong University, analyzes Hong Kong’s 2016–2017 budget, noting that the plan provides generous business tax incentives and leaves decisions on tax reform for another day. . .
UPDATE (3/4/2016): Hong Kong publishes tax bill: The Hong Kong government on March 4 published Inland Revenue (Amendment) (No. 2) Bill 2016, to implement the concessionary revenue measures proposed in the . . .
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