What We're Reading–MNE Tax

Americas

80+ US companies urge Congress to ratify pending tax treaties citing double taxation concerns: National Foreign Trade Council→

Africa

Kenya High Court strikes down Mauritius / Kenya tax treaty in TJN Africa action: Will Fitzgibbon / ICIJ→

For background, see: TJN Africa’s challenge to “loophole-ridden” Kenya-Mauritius tax agreement to be heard in Kenya High Court.

Asia-Pacific

BHP Billiton to appeal High Court in tax dispute involving Singapore marketing hub: Tom McIlroy / Financial Review→

American Samoa

Netherlands publishes tax ‘blacklist’ for CFC rules

January 8, 2019

Jian-Cheng Ku, Robin Theuns, and Rhys Bane of DLA Piper Nederland N.V., discuss the Dutch Ministry of Finance’s blacklist of low tax jurisdictions for controlled foreign company purposes. published December 28, 2018 . . .

Americas

Chile’s customs now accepts value set in APA: KPMG→

August 18, 2018

No Picture

Sweden, Denmark, Finland state opposition to EU digital services tax on revenue: Reuters→

Americas

US threatens 25 percent tariff on Chinese imports containing industrial significant technology: Zhenhua Lu / South China Morning Post→

Asia-Pacific

Australian tax authority challenging Exxon subsidiary’s intercompany loan interest deductions: Peter Ker / Financial Review→

Americas

US omnibus bill enacted, includes tax corrections but only one TCJA fix: Grant Thornton→

Asia-Pacific

Indonesia law gives tax authorities access to beneficial ownership of companies, other entities: The Jakarta Post→

No Picture

Jersey, Guernsey, Isle of Man to be considered for EU blacklist post-Brexit: New Europe→

January 16, 2018

Americas

Royal Dutch Shell, Barclays to show billions in paper losses from deferred tax assets drop due to US tax reform: Brady Quigley / Equities Focus→

January 4, 2018

No Picture

EU tax haven blacklist may force Jersey, Guernsey, Isle of Man to impose significant corporate tax: Richard Murphy / Tax Research UK→

December 6, 2017

Multinational

Tax Justice Network contests OECD tax haven list: Rick Mitchell / Bloomberg BNA→

Americas

Border adjustment just one of many options being considered to fix US international tax system, Mnuchin says: Sam Fleming, Demetri Sevastopulo & Shawn Donnan / Financial Times→

Americas

Professor considers Trump proposal for retaliatory tariff on imported goods from countries with import VAT: Richard Thompson Ainsworth / SSRN→

See: SSRN.

Americas

Patel, McClelland simulate impact of replacing of US corporate tax with DBCFT: Office of Tax Analysis→

January 30, 2017

See: Paper.

Americas

In state aid case, Ireland disagrees with Apple and US view that untaxed profits owed US: Simon Van Dorpe / EurActiv→

December 6, 2016

See: EurActiv.com.

Europe

UK’s first diverted profits tax demand involves royalty for offshore IP: Kevin Bell / Bloomberg BNA→

September 21, 2016

See: Bloomberg BNA.

Americas

Amici Curiae brief of 6 law professors in Altera case available; profs argue IRS stock-based compensation cost sharing regs are valid: SSRN→

August 17, 2016

See: SSRN.

Americas

US and OECD transfer pricing guidance compared: Robert T. Cole, William Byrnes / SSRN→

See: Practical Guide to U.S. Transfer Pricing § 2.01 – § 2.19, SSRN.

Multinational

OECD guidance on allocation of profit to PEs to address interaction with transfer pricing: Alex M. Parker / Bloomberg BNA→

See: Bloomberg BNA.

Europe

Barclays sale of Blackrock generates large Luxembourg tax loss: Tom Bergin / Reuters→

See: Reuters.

Digital Economy

France introduces 3% digital tax on revenue, hitting about 30 large internet companies: Elizabeth Schulze / CNBC→

More: France 24, Wall Street Journal, Fortune.

Africa

Egypt to adopt ‘revolutionary’ tax changes by 2020, will implement transfer pricing rules, finance minister says: Hagar Omran / Daily News Egypt→

December 18, 2018

Americas

Responding to Wayfair, US House members offer bill barring state tax collection on out-of-state sales until 2019: Bernie Becker / POLITICO→

September 17, 2018

Asia-Pacific

China to exempt foreign institutions from tax on bond interest: Bloomberg→

August 30, 2018

Europe

UK will tax digital firm revenue if international agreement on long-term tax fix is unsuccessful, Treasury official says: Pippa Crerar / The Guardian→

Europe

Ireland rebuffs EU proposal for digital firm tax: Arthur Beesley / Financial Times→

Multinational

Professor advocates moving to destination basis to tax business profits to confront digitalization: John Vella / University of Oxford→

February 21, 2018

Multinational

CbCR data does not reveal if MNE transactions are arm’s length, will likely be misinterpreted: Michelle Hanlon / SSRN→

February 14, 2018

Europe

UK hits Apple subsidiary with £136m (USD 184m) tax bill, marketing fee paid by related Irish company was too low: Vanessa Houlder / Financial Times→

January 9, 2018

Asia-Pacific

New Zealand tax department challenging 16 MNE’s transfer pricing, PE positions: Paul McBeth / The National Business Review→

December 11, 2017

Americas

France to appeal Google Ireland PE dispute: Fortune→

Americas

Like VAT, the DBCFT does not distort trade, Michael Devereux and Alan Auerbach argue: Forbes→

See: Forbes.

Americas

US professor critiques Treasury white paper on state aid: Daniel Shaviro / SSRN→

October 21, 2016

See: SSRN.

Asia-Pacific

Japan considers forcing professionals to disclose tax-saving methods – Nikkei Asian Review→

August 25, 2016

See: Nikkei Asian Review.

United Kingdom

UK unlikely to become post-Brexit tax haven, OECD’s Saint Amans says: Tom Bergin / Reuters→

See: Reuters.

Americas

Saint-Amans urges US to follow OECD/G20 BEPS recommendations: The Hill→

See: The Hill.

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