The OECD today released revised draft guidance on the attribution of profits to permanent establishments (PEs) as well as revised draft transfer pricing guidance on profits splits. Both discussion drafts replace earlier drafts . . .
Davide Anghileri of the University of Lausanne discusses an ECOFIN deal, reached May 23, for a directive that will create a new system for resolving double taxation disputes between the EU States; he also provides an update of EU discussions on adopting a common corporate tax base (CCTB) . . .
The Australian government today released draft diverted profits tax legislation, designed to stop large multinational businesses from artificially . . .
Davide Anghileri, a lecturer at the University of Lausanne, discusses a Court of Justice of the European Union decision which concludes that Portugal’s current practice of denying Portuguese companies a deduction for intercompany dividends received from Tunisian or Lebanese subsidiaries violates EU law . . .
Robert M. Gordon and Jennifer Crawford of True Partners Consulting LLC discuss the final US debt-equity regulations, focusing on the regs’ new documentation requirements for related party debt . . .
Italy’s tax authorities on September 26 issued a circular clarifying new rules on the deductibility of costs associated with transactions between Italian resident individuals or entities and businesses operating in blacklisted tax haven countries, writes guest author, Davide Anghileri . . .
The OECD today issued draft rules to be used by countries that seek to prevent multinational banks and insurance companies from avoiding tax through excessive interest . . .
The OECD has devised proposed criteria for determining if a country is a “non-cooperative” tax jurisdiction, an official said during a July 12 OECD webinar. OECD officials also discussed plans to release further tax and transfer pricing . . .
The OECD today issued further guidance implementing the new transfer pricing documentation and country-by-country (CbC) standards of action 13 the OECD/G20 base erosion profit shifting plan. The guidance is designed to ensure consistent implementation . . .
Medical device manufacturer Medtronic on June 9 won its transfer pricing dispute with the IRS in Tax Court, beating back the IRS’s claim that the medical device manufacturer should have reported increased US royalty payments and 2005 and 2006 from a related Puerto Rico . . .
Joel Cooper, co-head of international transfer pricing at DLA Piper, London, reports on a new WCO instrument that addresses use of transfer pricing documentation in assessing customs values. . . .
Davide Anghileri of the University of Lausanne discusses Court of Justice of European Union’s May 31 decision in Hornbach-Baumarkt which concluded that German transfer pricing legislation is valid and found that the role of the parent company as a shareholder of a non-resident company may be taken into account in assessing a non-arm’s length related-party transaction . . .
The European Commission on December 18 opened another State aid investigation into private tax rulings granted by an EU nation to a large multinational – this time the focus on whether the Netherlands grated special tax treatment to an IKEA subsidiary. The Commission is investigating Dutch tax rulings . . .
The US Senate early Saturday morning passed its version of tax reform on a 51-49 vote. Like the House bill, passed in November, the Senate bill’s international tax provisions would dramatically alter the taxation of US and foreign-parented multinationals. In a late change, the Senate increased the tax rate on deemed repatriations of currently deferred . . . .
The OECD on October 25 released public comments from 52 individuals and groups on the design of new international tax rules for digital firms. The comments aim to help an OECD task force prepare an interim report on the issue, to be presented to G20 finance ministers in April 2018. It is widely acknowledged that the current . .
Mumbai chartered accountant, Ajit Jain, discusses progress and problems with India’s advance pricing agreement (APA) program . . .
Indian tax officials signed a record number of advance pricing agreements (APAs) in fiscal year 2016–17; nonetheless, India’s backlog of unresolved APA cases increased during the . . .
Davide Anghileri of the University of Lausanne discusses an Italian law adopted April 24 that modifies Italy’s transfer pricing provisions to make them in-line with the OECD’s arm’s length principle, adds corresponding adjustments to Italian tax law, and updates the list of intellectual property that can qualify for the patent box regime . . .
Stefano Mariani and Calvin Ng of Deacons provide a comprehensive analysis of the tax proposals in Hong Kong’s budget 2017–2018, released today, which the authors argue do little to promote Hong-Kong’s long-term competitiveness . . .
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss final regulations released November 2 that clarify various issues arising under subpart F related concerning foreign partnerships and active rents and royalties . . .
Daniel Garabedian and Steven Peeters of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss in detail the expected features of the Belgian government’s planned innovation income deduction regime, which would replace the patent income deduction regime . . .
The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS . . .
The OECD today released 107 comment letters, mostly from business representatives, that respond to two OECD discussion drafts providing for common tax rules to be used to allocate multinational corporation profits among the countries in which they operate. Fifty-five comment letters relate to the OECD’s proposed revisions to its transfer pricing . . .
G20 finance ministers and central bank governors, during their July 23–24 meeting in Chengdu, China, approved a plan that sets out objective criteria to be used to label countries as “non-cooperative” for tax transparency . . .
As a part of its effort to address aggressive tax planning by large multinational groups, the UK government on May 12 launched a consultation on a proposal to introduce rules restricting interest . . .
Tax specialist, Ninja-Antonia Reggelin, discusses Monday’s German Parliament committee hearing on the proposed reform of the investment tax law, including measures to address tax avoidance in the German banking sector through dividend arbitrage. . .
India and Mauritius today signed a protocol to their 1983 tax treaty, revising the tax treatment of capital gains on sales by Mauritius residents of . . .
UPDATE: Text of the India/Mauritius protocol published: The text of the new protocl has been published on the Mauritius goverment website. See: Protocol.
The Australian Taxation office (ATO) has today released four alerts, warning multinationals that specified transactions will be heavily scrutinized for tax . . .
The US Treasury today announced a package of tax rules designed to discourage corporate inversions, including measures that restrict earnings stripping . . .
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