From the Firms–MNE Tax

Austria

Austrian law introduces transfer pricing documentation and country-by-country reporting: PWC→

August 10, 2016

See: PWC.

Asia-Pacific

Turkish tax law changes include raising corporate tax rate, reducing immovable property exemption, VAT on e-commerce: EY→

December 7, 2017

Africa

Dividends paid by Netherlands company to South Africa parent exempt from withholding, court rules: EY→

September 11, 2017

Americas

US Tax Court concludes payments to St. Kitts captive insurance company not deductible: Fox Rothchild→

August 28, 2017

Europe

French president-elect Macron’s proposed tax reforms: KPMG→

May 11, 2017

Asia-Pacific

Taiwan ruling details tax on cross-border e-commerce: EY→

May 5, 2017

Europe

Poland enacts law on country-by-country reporting: KPMG→

March 29, 2017

See: KPMG.

Americas

Canadian guide on country-by-country reporting released: EY→

March 22, 2017

See: EY. More: PWC.

Americas

Peru modifies transfer pricing laws: PWC→

January 26, 2017

See: PWC.

Cyprus

Cyprus guidance addresses VAT rules for active management holding companies: EY→

January 23, 2018

Europe

Finland court resolves two transfer pricing cases involving intragroup services: DLA Piper→

October 2, 2017

Europe

French plan lowers corporate rate, ends dividend distribution tax: PWC→

September 18, 2017

Asia-Pacific

Malaysia releases new transfer pricing guidance: KPMG→

July 12, 2017

Asia-Pacific

Australian legislation would impose GST on low value imports: EY→

March 1, 2017

See EY.

Americas

Brazil removes retroactive effective date for tax blacklist→

September 22, 2016

See: EY.

Denmark

Denmark issues final rules implementing BEPS transfer pricing documentation: Deloitte→

June 2, 2016

See: Deloitte.

Asia-Pacific

Singapore budget 2016 includes tax breaks for SMEs: Deloitte→

March 25, 2016

See: Deloitte. More: EY. Original sources: IRAS – Budget 2016 – Overview of Tax Changes, MOF – Budget 2016.

Asia-Pacific

Australian draft hybrid mismatch rules hit financing arrangements, branch mismatches: Alia Lum, Liam Delahunty & Stefan Hempelmann / KPMG→

March 12, 2018

Americas

Peru amends law to exclude OECD countries from definition of tax haven: EY→

January 23, 2018

Americas

Ecuador amends withholding tax rates: EY→

September 17, 2017

Europe

EU Court of Justice to determine legality of German anti-treaty shopping rules: Out-Law.com→

August 15, 2017

Swiss National Council supports notional interest deduction, patent box, R&D deduction: PwC→

March 29, 2016

See: PwC.

Americas

US files 9th Circuit appeal to reverse Altera, which invalidated cost sharing regs: Miller & Chevalier→

February 24, 2016

See: Miller & Chevalier. More: Daniel Shaviro, Deloitte .

Europe

Swedish court addresses transfer pricing benchmarking studies, use of interquartile range, hindsight: KPMG→

January 23, 2018

Americas

Cayman Islands lists reportable jurisdictions for CRS: KPMG→

April 5, 2017

Americas

Foreign captive insurance companies not exempt, IRS rules: KPMG→

March 29, 2017

See: KPMG.

Americas

Proposed US section 385 regs would have “profound impact,” recharacterizing routine related party debt transactions as equity as of April 4: PwC→

April 8, 2016

See: PwC. More: Skadden, Arps, Slate, Meagher & Flom.

Africa

Turkey to adopt transfer pricing documentation rules including CbC reporting: EY→

March 24, 2016

See: EY.

Asia-Pacific

Australian hybrid mismatch bill introduced into Parliament: EY→

May 30, 2018

Europe

Swedish tax plan would cut corporate rate, limit deduction for interest, hybrids: EY→

June 21, 2017

Americas

Colombia clarifies country-by-country reporting obligation: EY→

May 11, 2017

Americas

Panama updates transfer pricing documentation rules: PWC→

January 20, 2017

See: PWC.

Americas

Peru increases corporate rate, reduces dividend withholding tax: EY→

January 6, 2017

See: EY.

Americas

Canadian budget adopts CbC reporting and exchange of tax rulings, restricts back-to-back loans and royalties: Stikeman Elliott→

March 23, 2016

See: Stikeman Elliott. More: Osler, Hoskin, & Harcourt , Aird & Berlis, EY. Original source: Budget.

Americas

Ecuadorean law puts limits tax treaty benefits: PWC→

August 23, 2016

See: PWC.

Asia-Pacific

New Cambodian transfer pricing regulations cover documentation, audits: Duff & Phelps→

October 30, 2017

Asia-Pacific

Taiwan tax reform proposal would increase corporate, dividend withholding tax rates: Deloitte→

September 7, 2017

Denmark

Denmark tax ruling finds that foreign company had PE from service contract with Danish company: EY→

August 29, 2017

Europe

Russian draft guidance outlines bilateral APA procedure: DLA Piper→

April 7, 2017

RECENT COMMENTS

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin