Also, UK tax officials and Google reps have been summoned to appear at a Public Accounts Committee hearing February 11 to testify about the settlement. See: The Guardian.
The New Corporate Migration: Tax Diversion Through Inversion, by Cathy Hwang. See: SSRN.
See: Tax Legislation and the Notion of Fiscal Aid – A Review of Five Years of European Jurisprudence by Wolfgang Schön. (December 22, 2015). Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2015-14. Available at SSRN.
Source: ABC News (Australian Broadcasting Corporation), See also: Reuters, Wall Street Journal. For the report, see ATO. For explanatory material, see, ATO.
The Italian Parliament, on August 11, converted a series of tax incentives into law without modification, writes EY in an August 25 report. Included are increased notional interest deduction benefits, a tax credit for new plants and equipment, and an expanded withholding tax exemption for interest and substitute tax for loans. For discussion, see EY.
The European Commission on October 13 released a report “Tax Reforms in EU Member States: 2014.” See, report (7.34 MB), summary.
The amendment will be taken up by the Senate this week. See: Eurodad.
Professor Omari Y. Marian of the University of California, Irvine School of Law analyzes the “Lux Leaks” tax rulings, concluding that the Luxembourg tax authority, in exchange for payment, purposefully created legal differences between the tax laws of source and residence jurisdictions for multinationals to exploit. See: SSRN.
The OECD on October 31 released a discussion draft on the artificial avoidance of permanent establishment ( PE) status, addressing commissionaire structures, the avoidance of PE status through specific activity exemptions, and other issues. The draft responds to Action 7 of the OECD/G-20 Action Plan on Base Erosion and Profit Shifting (BEPS), issued
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UPDATE: OECD to hold January 21 consultation on draft rules to stop avoidance of PE status: Requests to attend or speak are due January 9.
Poland’s President, Bronislaw Komorowski, on Sept. 17, signed into law changes to the thin capitalization rules that reduce the debt-to-equity ratio to 1:1, broaden the definition of “qualifying entity,” extend the rules to indirect relationships, and introduce new methods to determine tax deducible interest limits, writes KPMG Poland in an Oct. 2 report. For discussion of the new law, see KPMG (PDF 126 KB).
See: Inversions and Competitiveness: Reflections in the Wake of Pfizer/Allergan by Reuven S. Avi-Yonh and Omri Y. Maria: SSRN.
See: Royalties in Australia: Task Technology and Seven Network Cases by Richard J. Vann: SSRN.
“Any retroactive tax would be borne by US taxpayers in the form of a credit,” notes US deputy assistant secretary, Robert Stack. See: Financial Times
The Guideline for Tax Risk Management of Fees paid to Overseas Related Parties, issued June 30, interprets Announcement 16, released in March, writes EY. See: EY
Taiwan’s Ministry of Finance has announced it will modify transfer pricing rules for business restructuring, the profit split method, and reporting for companies merged or dissolved, writes PwC in a March 19 report. Amendments also revise advance pricing agreement requirements and introduce reverse calculation of revenue using the profit standard of the same trade. See, PwC.
The Italian government on January 24 passed a law that significantly expands its new patent box regime, allowing additional categories of intellectual property and outsourced activities to qualify, and dispensing with the requirement to obtain a ruling to determine income attributed to IP in many cases, writes EY in a January 27 tax alert. See, EY.
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