Sam Olchyk and Arthur Norman of Venable LLP, Washington. discuss a May 24 US House Ways and Means Committee hearing on tax reform where lawmakers addressed the border adjustment tax, business deductions, and passthroughs . . .
Switzerland’s Federal Department of Finance today announced its new “Tax Proposal 17” initiative to reform the Swiss corporate tax code, writes Davide Anghileri of the University of Lausanne . . .
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
India and US tax officials have resolved 108 mutual agreement procedure (MAP) tax disputes and have reached agreement on the their first bilateral advance pricing agreement (APA), India’s Central Board of Direct . . .
Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses Italy’s budget 2017, approved by Prime Minister Matteo Renzi’s government October 15, which would lower Italy’s corporate tax rate and add provisions favorable to business . . .
The UK today launched a consultation proposing to fine accountants, tax planners, advisers, and others who enable tax avoidance. New rules were also proposed that would make it more likely that existing taxpayer . . .
Sandy Bhogal and Kitty Swanson of Mayer Brown, London, discuss a new law that extends the scope of the UK withholding tax on royalties to payments for the use of trademarks, trade names, and other assets . . .
The US IRS today issued final regulations requiring large US parented mulitnational corporations to file annual country-by-country (CbC) reports consistent with OECD/G20 base erosion profit shifting (BEPS) project guidance, though taxpayers that wish to file voluntary reports for the 2016 tax year with the IRS will . . .
Cyprus will sign the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting( MLI), Cyprus’s Ministry of Finance has announced . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump’s executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
Bhavik Timbadia and Hussain Sunel of BMR & Associates LLP discuss the newly revised draft UN Practical Manual on Transfer Pricing for Developing Countries, focusing on the India chapter, which reveals Indian tax authorities’ current transfer pricing positions, including some surprising views on low value adding intra-group services . . .
France’s Constitutional Council on December 29 struck down France’s controversial diverted profits tax law, finding it unconstitutional, and also determined that changes to the financial transaction tax are constitutional, writes Davide Anghileri of the University of Lausanne, a contributing editor at MNE Tax . . .
UK tax professional Tim Law discusses Autumn Statement 2016, released today, focusing on tax changes for large business. . .
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
Wiebe Dijkstra, Frank Pötgens, and Klaas Versteeg, of De Brauw Blackstone Westbroek, Amsterdam, analyze two mutual agreements recently concluded between the Netherlands and Switzerland concerning the taxation of collective investment vehicles, arguing that one of the agreements inappropriately prevents taxpayers from accessing the benefits of the Dutch-Swiss tax treaty . . .
Countries that integrate the OECD transfer pricing guidelines into their national laws should now begin to apply not only the recently approved OECD/G20 base erosion profit shifting (BEPS) plan transfer pricing changes, but should also interpret all . . .
Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium, discuss recent activities of the Inter-American Center of Tax Administrations (CIAT) and the State Secretariat for Economic Affairs of the Swiss Government (SECO) to assist tax administrations in Bolivia, El Salvador, Guatemala, Guyana, Honduras, and Nicaragua with transfer pricing and other issues . . .
UK Chancellor Philip Hammond in his Autumn Budget speech today proposed a new tax on multinational firms designed to primarily reach firms in the digital sector. The UK government also published a position paper outlining its thinking on the taxation of digital firms. Following consultation, the UK government . . .
Jitendra Jain, Executive Director, PricewaterhouseCoopers, discusses final Indian rules for multinational taxpayers, released October 31, on the implementation of the transfer pricing master file and country-by-country report, noting that important changes were made to the earlier, draft version of the guidance. . .
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
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