Professor Rifat Azam discusses a draft Israeli proposal that offers big tax incentives to large multinationals that invest in Israel, particularity IP and knowledge-based investments . . .
The Australian Taxation Office (ATO) has intensified its efforts to crack down on multinational corporation tax avoidance, launching a consultation on the aggressive use of offshore hub structures, and issuing taxpayer alerts on offshore permanent establishments . . .
Peter Dachs of ENSafrica, Cape Town, discusses proposed revisions to South Africa’s tax law, released 8 July, that would reverse the planned introduction of withholding tax on service fees and that would modify the tax treatment of hybrid debt, share incentive schemes, and trusts that provide interest-free loans . . .
Tax specialist, Ninja-Antonia Reggelin, discusses a proposed new German tax law to combat multinational profit shifting, which includes implementation of transfer pricing documentation and country-by-country reporting and exchange of tax rulings, as well as several other measures. . .
Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, discuss a new proposal to revise the Dutch innovation box regime, which provides a reduced tax rate for profits derived from intangibles . . .
The EU Commission on April 7 presented its VAT action plan, designed to update the EU VAT system to make it more fraud-proof, reduce administrative burdens, account for the digital . . .
Today the Council of the European Union removed Barbados, Grenada, the Republic of Korea, Macao SAR, Mongolia, Panama, Tunisia and the United Arab Emirates from the EU list of non-cooperative jurisdictions in taxation matters, writes Davide Anghileri of the University of Lausanne, Switzerland . . . .
The Hong Kong government on December 29 published a tax bill in its official gazette, proposing to introduce a transfer pricing regime and establish an advance pricing arrangement program. Inland Revenue (Amendment) (No. 6) Bill 2017 also adopts rules requiring transfer pricing documentation, including country-by-country reporting . . .
Mansi Seth and Joachim Saldanha of Nishith Desai Associates discuss an October 24 Indian tribunal decision which held that payments made by Google India to Google Ireland for marketing and distribution of online ad space through the Google’s AdWords program were royalty payments subject to withholding tax . . .
G7 finance ministers and central bank governors, following their May 12–13 meeting in Bari, Italy, said they may be able to back policy measures designed to ensure that tax challenges associated with the digitalization of . . .
The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN, and World Bank Group – on January 24 released a draft toolkit addressing ways that emerging economies can overcome lack of transfer pricing comparable data . . .
On December 19 the EU presidency released a proposal for the public disclosure of tax information by multinational groups, writes Davide Anghileri of the University of Lausanne . . .
The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company’s subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the OECD should improve the transfer pricing guidelines on intragroup services by reducing the number of group companies allocated low value centralised services, removing the benefits test, and providing guidance on high value services. . . .
Jian-Cheng Ku and Robin Theuns of DLA Piper, Amsterdam, analyze Netherlands transfer pricing guidance released April 22 ws.hich outlines the State Secretary of Finance’s interpretation of the arm’s length principle and reflects the Ministry’s views on amendments made to the OECD transfer pricing guidelines as a result of the BEPS project.. . . .
Davide Anghileri of the University of Lausanne discusses the EU’s tax blacklist, released December 5, which identifies 17 “non-cooperative jurisdictions” and warns many others that they could be listed in the future if they do follow through with commitments to improve specified aspects of their tax regimes . . .
Amanda Varma and Brigid Kelly of Steptoe & Johnson, Washington, discuss the implications of the US district court’s decision Starr International Co. Inc. v. US, issued August 14, where the court concluded that the US competent authority acted reasonably when it denied a taxpayer’s request for discretionary tax treaty benefits under the US-Switzerland tax treaty. . .
Tax advisors, accountants, banks, lawyers, and other intermediaries who design and promote potentially aggressive cross-border tax planning schemes and, in some cases, the clients that receive such advice, would be required to meet new reporting. . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Chau Huy Quang and Cao Dang Duy of Rajah & Tann LCT Lawyers, Hanoi, discuss a new Vietnam draft law which would establish uniform transfer pricing rules, including an expansive definition of “related party transactions,” and impose new conditions on the deductibility of common expenses arising between related parties, such as interest and service fees . . .
Facebook has filed a petition in US Tax Court, contesting IRS adjustments that increased the social media giant’s royalty income by about $85 million in 2010 on account . . .
The Swiss government has proposed to amend Switzerland’s withholding tax regime to facilitate the raising of capital by multinational groups, writes Davide Anghileri, PhD researcher and lecturer at the University of Lausanne in Switzerland . . .
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