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OECD releases 28 comments to draft on tax treaty residence of pension funds
The OECD on April 6 released public comments to a discussion draft intended to clarify the tax treaty residence of pension funds. The discussion draft, part of follow-up work . . .
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Europe
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Comments released on tax guidance addressing offshore indirect asset transfers
18 comment letters – including letters from the governments of India and China — were released today responding to a draft “toolkit” designed to help developing countries address the taxation of offshore indirect transfers of assets, a practice used by some multinational corporations for tax avoidance. The guidance was prepared by “Platform for Collaboration on Tax,” a joint effort of the IMF, UN, OECD, and . . . .
Europe
Jersey to consider new “substance test” for tax residence following Appleby leak
The government of Jersey on November 8 announced that it may amend its tax laws to add a substance test for tax residence, responding to allegations that the island nation is being used for tax avoidance by multinationals, including Apple. On Sunday, the International Consortium of Investigative Journalists published a trove of leaked . . .
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Australia expects large tax recoveries from seven multinational firm audits, Jordan says
The Australian Taxation Office (ATO) expects to conclude tax audits of at least seven major multinational firms by June 30, likely assessing combined tax liabilities in excess . . .
Americas
US Sens. Sanders, Schatz introduce tax bill to end deferral of multinational profits, close loopholes
US Senators Bernie Sanders (I-Vt.) and Brian Schatz (D-Hawaii) today introduced a tax bill designed to curtail . . .
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Switzerland launches consultation on exchange of multinational corporation country-by-country tax reports
Switzerland’s Federal Council on March 13 initiated a consultation on legislation that would give effect to a multilateral agreement signed . . .
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India to accept transfer pricing APA, MAP applications even if corresponding adjustment treaty provision absent
The Indian government today clarified that it will accept transfer pricing mutual agreement procedure (MAP) cases and bilateral advance pricing agreement applications in situations where the applicable tax treaty does not include a provision comparable to Article 9(2) of OECD Model Tax Commentary, providing for corresponding adjustments. A Central . . .
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Europe
France’s withholding tax on dividends paid to EU subsidiaries violates EU law, Commission says
The EU Commission today notified France that it considers France’s withholding tax on dividends paid to subsidiaries located in other EU States or European Economic Area (EEA) Members States to be contrary EU law. The Commission said . . .
Asia-Pacific
UAE signs multilateral treaty to fight offshore tax evasion and multinational corporation avoidance
The United Arab Emirates on April 21 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 109th jurisdiction to participate in the convention. The treaty, developed in 1988 by the OECD and the Council of Europe, would enable . . .
Europe
EU court to review German law denying withholding tax exemption for some dividends paid to foreign parents
The European Court of Justice has published a reference for a preliminary ruling in a case challenging a German law that denies relief from withholding tax on some distributions . . .
Americas
IRS issues tax guidance on US source dividend equivalent payments
The US Internal Revenue Service has today published final and temporary (TD 9815) and proposed (REG-135122-16) tax regulations providing guidance to nonresident alien individuals and foreign corporations that hold financial products providing for payments. . .
Europe
Russia investigates IKEA Germany for tax fraud from stock sale of Russian subsidiary
Russia’s Investigation Committee has again launched a criminal probe alleging that IKEA’s German division committed tax fraud when it failed to pay taxes upon its sale of stock in a Russian . . .
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