From the Firms–MNE Tax

Americas

Dominican Republic tax authorities requesting documentation to verify transfer pricing, loans: KPMG→

March 19, 2018

Americas

US tax act’s amendments to CFC stock attribution rules change treatment of US private companies with foreign investment: EY→

February 6, 2018

Africa

Nigeria publishes country-by-country reporting regulations: KPMG→

September 24, 2018

Africa

Egypt amends transfer pricing rules: EY→

June 13, 2018

Europe

Spain applies MLI to 86 tax treaties, opts for mandatory binding arbitration: EY→

June 15, 2017

Europe

France proposes diverted profits tax: EY→

November 26, 2016

See: EY.

Americas

New Mexican APA rules allow tax authority site visits: PWC→

August 7, 2016

See: PWC.

Europe

Russian draft law introduces country-by-country reporting: EY→

April 21, 2016

See: EY.

Americas

New York bill would remove GILTI income from state and local tax computation: Eversheds Sutherland→

June 13, 2018

Americas

Brazil removes Costa Rica, Madeira, Singapore from tax haven list, but adds regimes to “privileged”list: KPMG→

January 17, 2018

Americas

Ecuador adds Hong Kong to tax haven blacklist: EY→

August 28, 2017

Americas

Argentina suspends new rules for taxing nonresident capital gains: KPMG→

August 3, 2017

Americas

Bahamas budget includes reduction in business license tax: KPMG→

June 29, 2017

Americas

Canada takes conservative approach to multilateral instrument: Gowling WLG→

June 15, 2017

Asia-Pacific

China signs first APA for cost sharing agreement: PWC→

March 16, 2017

See: PWC.

Europe

New Luxembourg transfer pricing rules may require documentation revision: KPMG Luxembourg→

March 2, 2017

See: KPMG Luxembourg.

Swiss Canton Vaud backs 13.8 percent corportate tax rate from 2019: Froreip→

March 29, 2016

See: Froreip. More: MME Legal, Swissinfo.

Asia-Pacific

Payments received by Luxembourg company from Indian hotel for managing and operating the hotel attributable to Indian PE, tribunal rules: PWC→

June 12, 2018

Americas

Canada to require 2016 CbCR constituent entity filing for Canadian subs parented in countries without exchange agreement: PWC→

January 9, 2018

Americas

US Senate bill’s last minute corporate AMT addition effectively repeals participation exemption, reduces GILTI and FDII benefits: Davis Polk→

December 6, 2017

Americas

El Salvador publishes annual tax haven list; payments to listed countries incur increased withholding: EY→

October 10, 2017

Asia-Pacific

Thailand government advances draft transfer pricing law: KPMG→

June 20, 2018

Europe

Dutch court puts burden of proof on tax authority in transfer pricing case because taxpayer prepared documentation: Baker McKenzie→

October 20, 2017

Americas

US IRS clarifies research credit safe harbor for taxpayers reporting R&D expense on financial statements: PWC→

September 23, 2017

Belgium

MLI choices made by the Netherlands, Belgium, Luxembourg and Switzerland: Loyens & Loeff→

June 15, 2017

Asia-Pacific

Saudi Arabia excise tax law published: EY→

June 1, 2017

Americas

US government temporarily halts issuance of new tax guidance: KPMG→

January 26, 2017

See: KPMG .

Europe

Luxembourg director fees are subject to VAT: Allen & Overy→

March 29, 2016

See: Allen & Overy.

Asia-Pacific

Malaysian guidance addresses taxation of online advertising provided by non-residents: EY→

April 10, 2018

Americas

Argentina tax reform adds sixth method, other transfer pricing revisions: KPMG→

January 8, 2018

Asia-Pacific

Japanese tax reform proposal would enhance R&D credit, reform CFC and reorganization rules: PWC→

December 14, 2017

Estonia

Estonian corporate tax reform includes reduced tax rate for dividend payments: EY→

June 28, 2017

Polish court confirms pre-2017 services by nonresidents subject to withholding tax: EY→

May 31, 2017

Europe

Netherlands Supreme Court rules on tax deductiblity of intercompany interest, tax penalites: Loyens & Loeff→

April 21, 2017

Americas

Chile issues guidance on new tax regime: Deloitte→

August 7, 2016

See: Deloitte.

Europe

Italy issues new circular on patent box regime: EY→

April 15, 2016

See: EY

Europe

Finland issues transfer pricing rules for intragroup services: KPMG→

October 18, 2017

Asia-Pacific

Vietnam proposal provides tax incentives, lower corporate and personal rates, expands VAT: KPMG→

September 17, 2017

EU Court of Justice Advocate General concludes Finnish exit tax violates EU law: KPMG→

July 17, 2017

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