India and Japan are poised to resolve about 15 transfer pricing disputes under the mutual agreement procedure involving the automobile industry and large trading houses, writes Jayshree P Upadhyay of the Business Standard in a May 27 article. India also expects to soon resolve transfer pricing disputes involving the UK and France. See, Business Standard.
Former PwC auditor, Antoine Deltour, was charged with multiple crimes in Luxembourg on December 12 for stealing and leaking confidential PwC client advance tax rulings and other documents that were later placed on the Internet by the International Consortium of Investigative Journalists (ICIJ). He has admitted his involvement, but says that he did not provide all the material released on the ICIJ website. See, Blomberg, The Guardian, Luxemburger Wort, The Irish Times.
The Indian government intends to defer implementation of its general antiavoidance rules (GAAR) to avoid harming investor confidence, and will likely make an announcement to that effect in the 2015-16 budget, writes the Times of India in a February 14 article, quoting an unnamed source. See, Times of India, See also, Financial Express, The Economic Times.
A bill introducing a patent box regime in Italy consistent with the OECD’s nexus approach was submitted to the Italian Parliament in October, writes PwC in a December 2 article. PwC notes that to be eligible for tax benefits under the bill, most taxpayers would need to enter into an advance pricing agreement with revenue authorities. For a detailed discussion of the new provisions, see PwC. See also, DLA Piper, Società Italiana Brevetti
Pascal Saint-Amans, the director of the OECD Centre for Tax Policy and Administration, addressed Ireland’s recent tax announcements and his views on whether the US will implement or block the OECD/G-20 base erosion profit shifting measures during an interview with the Irish Independent. See, Irish Independent.
Sutherland Asbill & Brennan LLP has provided a report of a July 28 meeting of the Multistate Tax Commission’s Arm’s Length Adjustment Services Advisory Group, which is creating a transfer pricing model for the U.S. states and is considering ways to improve the states’ ability to analyze intercompany transactions. See, Sutherland SALT report.
Professor Gabriel Zucman of UC Berkley, in his book, The Hidden Wealth of Nations, concludes that corporate and individual use of tax havens is increasing rapidly. See: Gabriel Zucman. Reviews: The Wall Street Journal, Bloomberg, Huffington Post.
The United States Council for International Business has written to US Treasury, arguing that draft provisions in the US model tax treaty released last May “tilt too far in their attempt to prevent inappropriate claims of treaty benefits.” The group is concerned with provisions on special regimes, subsequent changes in law, and limitation on benefits. See: USCIB. Related: MNE Tax.
Spain has approved a more generous special tax regime for companies operating in the Canary Islands which includes an extension of the 4 percent corporate income tax rate to all of a company’s taxable income if conditions are met, writes PwC in an April 29 tax alert. See, PwC.
The National Taxation Bureau of Taipei, Ministry of Finance, (NTBT) on November 7 provided an English-language description of NTBT regulations on the process foreign businesses should use to apply to exempt profits from taxation pursuant to a tax treaty. Taiwan release.
A tax bill tabled in South Africa’s parliament on October 22 proposes taxpayer-favorable changes to Section 23M of the Income Tax Act, which limits interest that can be deducted on loans from a person that is an a “controlling relationship,” with the debtor, notes KPMG in an October report. For details, see KPMG.
Sutherland Asbill & Brennan LLP has provided a detailed account of an October 6 meeting of the US Multistate Tax Commission’s Arm’s Length Adjustment Services Advisory Group, where seven external economic firms provided advice on ways the MTC could assist states with their transfer pricing challenges. For detailed discussion, see Sutherland Asbill & Brennan.
Sen. Rand Paul, a Kentucky Republican, and Sen. Harry Reid, a Nevada Democrat, are advocating for a one-time repatriation tax holiday for multinationals to replenish depleting federal highway funds, according to a June 9 article by Jonathan Weisman, New York Times.
Despite heavy lobbying by domestic retailers, Russia will only enact minor increases to customs taxes for online cross-border sales, reports Adrien Henni, in the June 2 edition of East-West Digital News.
The authors, both professors at Vienna University of Economics and Business, interviewed 61 Austrian tax experts, asking them to identify which OECD/G20 BEPS actions they believed would be most effective in combating multinational tax avoidance. See: SSRN
Taiwan’s tax authority, in an English-language release issued January 8, provided a brief description of transfer pricing disclosure and documentation requirements that must be met by profit-seeking enterprises when filing their annual income tax return. See, release.
Russian President Vladimir Putin on December 1 signed addendums to the country’s tax code providing enhanced tax benefits to residents of the free economic zone in Crimea, Russian news agency TASS has reported. Under the new provisions . . .
The Australian tax office (ATO) has revoked six advance pricing agreements (APAs) with multinationals within the last six months because the government had been misled and the companies were engaging in aggressive tax planning, reports Nassim Khadem of the Brisbane Times in a November 7 report, quoting ATO deputy commissioner, Mark Konza. Konza also said the ATO is reviewing the activities of 80 high risk multinationals. See, Brisbane Times.
The Qatar Financial Centre Authority has released an updated version of the Qatar financial centre (QFC) tax regulations, writes EY, in an August 11 report. For an analysis of the new regulations, see, EY.
US firm, Illinois Tool Works Inc, has petitioned Tax Court to challenge the IRS’s decision to recharacterize a loan from its Bermuda subsidiary to a US affiliate as a taxable repatriation of profits, writes Patrick Temple-West, Reuters.
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