G20 finance ministers and central bank governors, in a communique following their March 17–18 meeting in Baden-Baden, Germany, called on an OECD task force to produce an interim . . .
Switzerland’s Federal Council today mandated that the Federal Department of Finance (FDF) prepare a new corporate tax reform proposal by mid-2017, following the rejection of corporate tax reform III in a popular referendum earlier this month, writes Davide Anghileri of the University of Lausanne. . . .
Julian Feiner of Dentons, London, discusses draft UK proposals, released yesterday, that would change the taxation of carried-forward losses and interest deductions . . .
The OECD has today released for public comment three draft examples addressing the application of the OECD/G20 base erosion profit shifting (BEPS) Action 6 principal purpose test to . . .
The EU Commission has been asked to prepare draft legislation for a financial transaction tax (FTT) following significant progress made on the design of the tax . . .
The Obama Administration, in a letter and white paper released today, ramped up its criticism of European Commission efforts to force large multinational firms to pay back amounts deemed illegal state aid that were allegedly received through overly generous tax rulings, known . . .
Daniel Chan, Windson Li, and Henry Ji, of DLA Piper, Hong Kong, provide a comprehensive overview of key Chinese transfer pricing documentation, inter-company transaction reporting, and country-by-country reporting rules, which were adopted on July 13 . . .
Tax officials provided an update of international tax and transfer pricing guidance currently being developed at the OECD, including work on profit splits and on attribution of profits to permanent establishments (PEs), at Washington DC conference sponsored by the OECD, USCIB, and . . .
The International Monetary Fund, OECD, United Nations, and World Bank Group today released a concept note outlining their plan to work together to help governments address the tax policy . . .
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze Dutch Supreme Court decisions issued March 4 in Miljoen, X, and Société Général, concerning the calculation of dividend withholding tax refunds due portfolio investors . . .
The European Commission today unveiled new tax proposals aimed at establishing a coordinated EU-wide approach to curb to multinational tax avoidance. The anti-tax avoidance package, or ATAP, includes a proposed directive for . . .
Konstantin Sakuth of Linklaters LLP, Munich, discusses a June 28 European Court of Justice decision which settled a long-running debate regarding the legality under EU State aid rules of Germany’s “restructuring clause,” which allows carryback of tax losses following some company restructurings . . .
Jim Stewart, an Adjunct Professor in Finance at Trinity Business School, Trinity College, Dublin, writes that Irish budget 2018, released today, proposes to limit deductions for intellectual property expenditures, but contains few other changes directly affecting the Irish corporate tax regime . . .
Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .
The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
Mansi Seth, head of Nishith Desai Associates’ US practice, and Ashish Sodhani, a senior member of the firm’s international tax practice, discuss the renegotiated India-Cyprus tax treaty, which provides for source-based taxation of capital gains arising from alienation of shares . . .
Davide Anghileri of the University of Lausanne discusses the European Commission’s December 1 proposal to modernize and unify throughout Europe the value added tax (VAT) rules for cross-border business-to-consumer (B2C) e-commerce . . .
Officials are putting the finishing touches on the multilateral instrument (MLI) to implement the OECD/G20 base erosion profit shifting (BEPS) measures, keeping it on track to be finalized this fall, senior . . .
The EU Economic and Financial Affairs Council (ECOFIN) today formally adopted without discussion the Anti-Tax Avoidance Directive (ATAD), designed to tackle multinational corporation tax . . .
Leaders of the G-7 nations of the US, UK, Canada, France, Japan, Germany, and Italy, following their meeting in Ise-Shima, Japan, vowed to “lead by example” by implementing the OECD/G20 base erosion profit shifting (BEPS) package in . . .
G20 finance ministers, during their February 26–27 meeting in Shanghai, approved an OECD-developed plan to allow all countries to participate in the implementation of base erosion profit shifting (BEPS) . . .
The European Commission will likely propose EU-wide legislation requiring large multinationals to publicly report their European profits and . . .
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