The US IRS in late December issued a slew of FATCA guidance, including updated agreements for foreign financial institutions and qualified intermediaries (QIs). Included in the release were . . .
As part of an effort to devise an EU-wide common list of tax havens, the EU Commission today released a scoreboard designed to help identify countries located outside the EU that enable multinational corporation tax avoidance. Eighty-one countries – including the US, China, and India – were identified. . .
India and Cyprus have completed negotiations for a new tax treaty that allows for source-based taxation of capital gains from the alienation of shares and have agreed to Cyprus’s removal from India’s blacklist of “notified jurisdictional areas,” Cyprus’s . . .
The OECD today released peer reviews assessing whether 44 countries have met their commitments to disclose information to other countries about the private tax rulings they grant to multinational firms. The commitments, made as a part of 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements between . . .
Sam Olchyk and Kiley Boland, Venable LLP, Washington discuss the a US Senate Finance Committee hearing held October 3, where tax professors expressed discontent with the current US international tax system and agreed that American companies are treated unfairly in comparison to foreign companies operating in the US . . .
A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18. Michael Lennard . . .
The OECD today outlined the peer review process to be used to assess countries’ compliance with minimum standards set out in the OECD/G20 base erosion profit shifting (BEPS) plan on tax . . .
The Australian Taxation Office on May 16 issued draft guidelines on cross-border related party financing arrangements. In the . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about difficulties applying the House GOP’s destination-based cash flow proposal to partners and partnerships . . . .
The European Commission is scrutinizing advance pricing agreements (APAs) issued to financing companies and to other businesses for potential state aid violations EU competition commissioner Margrethe . . .
Anne Fairpo of Temple Tax Chambers discusses proposed UK tax law changes that would subject more categories of royalty payments to withholding tax . . .
European Union finance ministers today reached political agreement on requiring EU-wide country-by-country reporting by multinational corporations and on sharing that data between tax administrations. It was also revealed today that any future. . .
Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, offer a detailed analysis of the UN Committee of Experts on International Cooperation in Tax Matters’ April 8 a draft chapter on financial transactions, proposed as an update to the UN Practical Manual on Transfer Pricing for Developing Countries . . .
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .
An Indian appellate court has ruled that payments made by Google’s Indian subsidiary to Google’s Irish subsidiary to operate the Google AdWords program in India were royalties subject to withholding tax and not payments to obtain advertising space for resale, as Google has claimed. The court also mandated the use of the profit split method for some related-party transactions. . .
US IRS and Treasury officials joined tax practitioners and corporate tax executives today to discuss key international tax and transfer pricing developments at the 30th Annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the Internal Revenue . . .
Dimitrios Kyriazis of the New College of the Humanities and University of Oxford discusses today’s news that the EU Commission has adopted a negative decision in the Amazon fiscal State aid case and the Commission’s argument that a departure from the arm’s length principle amounts to the conferral of an advantage to the recipient . . .
The “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and the World Bank – today published the final version of a toolkit designed to provide developing . . .
Italian legislation proposed May 22 is designed to increase tax collection from foreign multinationals that have online activities Italy, writes Davide Anghileri of the University of Lausanne . . .
The European Court of Justice (ECJ) has ruled that a criminal proceeding can be brought against the legal representative of a company even if the company has already paid a tax penalty with respect to the same act or omission, writes Davide Anghileri of the University of Lausanne . . .
Tax officials, during a March 28 webcast, discussed the OECD’s international tax agenda, including plans to release tax and transfer pricing guidance and promote . . .
Davide Anghileri of the University of Lausanne discusses Italy’s new country-by-country reporting requirements for large multinationals . . .
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