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Indian secondary adjustments for transfer pricing: what you need to know about the new rules
India transfer pricing and tax litigator Ajit Jain discusses new transfer pricing rules providing for secondary adjustments . . .
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OECD releases 33 comments to draft guidance on tax treaty access by non-CIV funds
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Asia-Pacific
Australian diverted profits tax legislation introduced
Julian Feiner of Dentons, London, discusses proposed Australian legislation, introduced into Parliament February 9, that would implement a diverted profits tax, comparing the draft to the UK DPT . . .
Europe
Apple appeals State aid decision in EU court
Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, Galway, provides an update of the EU Commission’s State aid challenge to tax rulings granted by Ireland to Apple . . .
Africa
India-Mauritius tax treaty re-negotiated: what it means for international business
Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Shipra Padhi, a senior international tax specialist based in the firm’s Mumbai office, discuss how the taxation of foreign investment in India will change as a result of the renegotiation of the India-Mauritius tax treaty . . . .
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Tax proposals in Indian budget affect international business, experts say
India’s Budget 2016–17, offered today by Finance Minister Arun Jaitley, includes a number of tax measures of interest to international business, according to tax specialists . . .
Europe
EU finance ministers wary of anti-tax avoidance proposal
EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for . . .
Americas
US and India to begin negotiating bilateral APAs, 100 transfer pricing disputes resolved
Reassured by the successful settlement of numerous long-pending transfer pricing disputes, the US competent authority has agreed to soon begin negotiating bilateral advance . . .
Update (2/1/2016): US confirms it will accept Indian bilateral APA applications: The US IRS, on February 1, confirmed that, beginning February 16, the US competent authority will accept applications . . .
Europe
UK Treasury minister defends Google tax settlement
UK Treasury Secretary David Gauke today defended an HM Revenue and Customs settlement with Google relating to back taxes, telling Members of Parliament that the company . . .
Europe
Luxembourg law adapting corporate tax code to EU law contains gaps
Paloma Schwarz Martínez, a PhD Researcher at the University of Luxembourg, analyzes Luxembourg’s new law implementing changes made to the EU Parent-Subsidiary directive, noting that restrictions on hybrid mismatch arrangements and new antiabuse rules will not apply when non-EU companies are involved in a transaction.
Europe
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Why France’s appellate court concluded that ValueClick’s French subsidiary did not have a PE in France
Terence Wilhelm, managing partner of CARA Avocats, Lyon area, France, discusses key takeaways from the Paris Administrative Appeal Court’s recent decision in ValueClick, where the court adopted a restrictive view of the concept of permanent establishment applying the applicable French tax treaty based on the old OECD model . . .
Europe
OECD model tax treaty shouldn’t guide EU law on beneficial ownership, Advocate General says
The EU Advocate General of the Court of Justice of the European Union, Juliane Kokott, on March 1, released her opinion in four cases dealing with the interpretation of the beneficial ownership concept where the Interest Royalty Directive applies and in two cases where the Parent-Subsidiary Directive applies, writes Davide Anghileri of the University of Lausanne . . .
Europe
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Report details UN Committee of Experts’ fourteenth session on international tax
An official report describing the outcome of the fourteenth session of the UN’s Committee of Experts on International Cooperation in Tax Matters (Committee of Experts) was released on the UN website this week. The fourteenth session . . .
Europe
France’s additional tax on dividends is contrary to law, EU court concludes
The European Court of Justice in May 17 decision ruled that France’s additional tax on dividends is not compatible with article 4 of the parent-subsidiary directive, writes Davide Anghileri of the University of Lausanne . . .
Asia-Pacific
Indian POEM – not so poetic! An analysis of India’s new place of effective management rules
Ashish Sodhani and Ameya Mithe of Nishith Desai Associates provide a comprehensive analysis of India’s new guidelines for determining a foreign company’s place of effective management . . .
Europe
Apple to argue in State aid case that Irish subs’ profits belong to US
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission’s State aid decision against Ireland, published today in summary form, noting that Apple’s arguments diverge somewhat from Ireland’s arguments. . .
Europe
France’s denial of dividend withholding tax exemption under EU scrutiny
The ECJ Advocate General in a January 19 opinion concluded that France’s use of GAAR to deny a withholding tax exemption for dividends distributed by a French company to its Luxembourg parent is incompatible with EU law, writes MNE Tax contributing editor, Davide Anghileri of the University of Lausanne . . .
Europe
EU Commission releases opening decision in State aid probe of Luxembourg tax rulings granted Engie
The European Commission today published a non-confidential version of its decision to open a State aid investigation into whether a tax rulings granted by Luxembourg to Engie, formally known as GDF Suez . . .
Africa
BRICS: tax policies should enhance growth, address BEPS
BRICS leaders, following their summit held October 15–16, called for tax policies that promote inclusive growth and expressed support for the implementation of the OECD/G20 base erosion profit shifting . . .
Americas
Final earnings stripping regulations released
The US Treasury Department on Thursday released final earnings stripping regulations under section 385, resisting calls by business and Republican lawmakers to slow down . . .
Europe
Switzerland’s Canton of Zug to offer 12 percent corporate tax rate, patent box, R&D break
Swiss tax expert Davide Anghileri discusses the cantonal government of Zug’s September 19 announcements outlining corporate tax reform III, designed to create a tax environment that maintains the canton as an attractive place to invest but also bring it in-line with international tax standards . . .
Americas
Business reps urge overhaul of US debt/equity proposed regulations at hearing
Sam Olchyk and Arthur Norman of Venable LLP, Washington, report on a July 14 IRS hearing on controversial proposed section 385 earnings stripping regulations, noting that the speakers advanced a number of compelling arguments in favor of modifying the tax regulations, but IRS and Treasury officials remained mostly silent, not revealing their plans regarding the regulations . . .
Europe
German Federal Assembly wary of public release of country-by-country transfer pricing reports on multinationals
Tax specialist, Ninja-Antonia Reggelin, discusses the state of play in Germany regarding a Commission proposal for public release of country-by-country reports on multinationals . . .
Europe
Luxembourg announces corporate tax rate cut
Luxembourg is planning to lower its corporate tax rate over the next two years, writes Paloma Schwarz Martínez, a PhD researcher at the University of Luxembourg. . . .
Americas
US tax regulations extend foreign financial asset reporting to domestic entities
Michael J. Miller of Roberts & Holland, New York, reviews final US regulations, released February 23, that require domestic corporations, partnerships, and trusts to report their foreign financial assets to the IRS . . .
Council of the European Union
EU ‘minimum effective taxation’ of interest, royalties among Dutch Presidency’s BEPS priorities
The Dutch Presidency of the EU hopes to achieve political agreement in the coming months on adding a clause on minimum effective taxation (MET) to the interest and royalties directive, according to a roadmap of the . . .
Europe
EU Commission VAT action plan coming in March, says Dijsselbloem
The EU Commission will offer in early March an action plan proposing VAT simplification and anti-VAT fraud measures, including an option for a reverse charge mechanism, officials. . .
Americas
Mexico transfer pricing comparability adjustments, the search for consensus
Jesús Aldrin Rojas a partner at QCG Transfer Pricing Practice, Mexico City, provides a comprehensive overview of a recent conference sponsored by the Universidad Panamericana Campus Mixcoac where Mexican tax officials and transfer pricing practitioners discussed new Mexican transfer pricing guidance . . .
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