The OECD on July 11 released a discussion draft requesting stakeholder feedback on issues associated with drafting model tax guidance on a group ratio rule for use by countries that wish to address multinational corporation tax . . .
The EU Commission today published the non-confidential version of its decision concluding that an advance pricing agreement (APA) granted to a Fiat subsidiary by Luxembourg is illegal . . .
Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, follow up on their article on the 2019 Dutch budget, noting that the Netherlands government has now published a proposed a list of jurisdictions qualifying as “low-tax jurisdictions” for purposes of the proposed source tax and the CFC rules . . .
MNE Tax contributing editor, Davide Anghileri, discusses a Council of the European Union May 25 meeting where EU States agreed on new rules for regulating intermediaries that design or promote tax planning schemes; new wording to be included in agreements with third countries on good governance in tax matters; and moving the Bahamas and Saint Kitts and Nevis from the EU’s tax blacklist list to its “gray list” . . . ,
Eugene Lim of Providence Law Asia LLC discusses new updates to Singapore transfer pricing guidance, issued February 23, setting out enhancements to the arm’s length principle, adding new transfer pricing documentation requirements, and granting new powers of the Comptroller of Income Tax to make transfer pricing adjustments and impose surcharges and penalties for non-compliance . . .
The OECD has issued new tax guidance on the common reporting standard, including the CRS XML schema, writes Davide Anghileri of the University of Lausanne . . .
Davide Anghileri, of the University of Lausanne, discusses an EU Council compromise agreement, reached today, on a directive addressing hybrid mismatches involving non-EU countries . . .
Davide Anghileri of the University of Lausanne discusses an October 27 EU Commission working paper on debt bias tax systems of the EU member states which concludes that reform can be revenue neutral and maintain EU investment . . .
An EU Commission paper released October 27 uses economic modelling to conclude that recent EU proposals for a common corporate tax base (CCTB) and a common consolidated corporate tax base with formula apportionment (CCCTB) would result a fairer and more efficient tax system, writes Davide Anghileri, of the University of Lausanne, Switzerland . . .
The OECD has released 17 comment letters responding to a draft report that explores how countries can improve their tax laws to counteract tax avoidance by multinational enterprises (MNEs) through . . .
US Treasury’s plan to revise six problematic areas in the proposed section 385 debt-equity regulations does not go far enough to allay concerns about regs’ negative impact on the US economy, Republican lawmakers . . .
Goodmans LLP tax attorney, Kabir Jamal, provides an analysis of the international tax proposals in the Canadian government’s draft tax bill, issued July 29, including measures that address foreign exchange gains on foreign-currency debt, back-to-back loan and royalty arrangements, and country-by-country reporting . . . .
The issue of tax certainty will be addressed by the G20 when Germany takes up its presidency in 2017, said Martin Kreienbaum, Director General, International Taxation, at Germany’s Federal Ministry of Finance at the 2016 OECD International Tax Conference . . .
The EU Commission on June 3 released a working paper identifying several categories of Member State transfer pricing rulings that raise potential State aid concerns because they sanction profit allocations. . .
South Africa’s 2016 budget includes a measure to curb perceived abuses associated with hybrid debt instruments and a warning about future action on share buybacks, writes South African tax practitioner, Peter Dachs . . .
As expected, the EU Commission will need to defend in court its contention that advance pricing agreements (APAs) granted to a Starbucks subsidiary by the Netherlands and to a Fiat subsidiary by Luxembourg . . .
Francisco Lisboa Moreira, a partner with Bocater, Carmargo, Costa e Silva, Rodrigues, São Paulo, provides an update of recent Brazilian tax developments of interest to MNEs, discussing new Brazilian transfer pricing guidance and the Brazilian Congress’s approval of protocol to the Brazil-Denmark tax treaty . . .
Davide Anghileri writes about the opinion of the Advocate General of the Court of Justice of the European Union in the Bevola case, delivered January 17, which concludes that a Danish law that precludes the deductibility of final losses incurred by a company’s foreign permanent establishment violates EU law . .
The Australian government on November 24 released a draft law and explanatory materials implementing hybrid mismatch rules to combat multinational firm tax avoidance. The Australian government is also developing a “targeted integrity rule” to prevent circumvention of the hybrid mismatch rules as well as branch mismatch rules to further clamp down on MNE tax . . .
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