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South Africa identifies taxes qualifying for tax treaty relief
Davide Anghileri of the University of Lausanne writes about new guidance issued by the South African Revenue Service that identifies taxes that are similar to income taxes and thus qualify for tax treaty relief . . .
Austria
Multinationals asked to critique tax dispute resolution processes in Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden
The OECD has today asked global businesses to assess the mutual agreement procedure (MAP) for resolving tax treaty disputes in Austria, France, Germany, Italy . . .
Americas
US IRS issues final tax regulations on disregarded stock in inversions
The US IRS has published final and temporary (TD 9812) and proposed (REG-135734-14) tax regulations under section 7874 designed to fight tax avoidance associated with the inversion . . .
Asia-Pacific
India clarifies taxation of indirect transfers of assets abroad
India on December 21 set out a series of questions and answers clarifying the taxation . . .
Americas
New Zealand proposes rules to combat multinational tax avoidance through use of hybrid mismatches
The New Zealand government has today released for discussion proposed measures to prevent multinational corporations from avoiding tax through use of hybrid mismatch . . .
Asia-Pacific
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Europe
Ireland extends country-by-country filing deadlines
Ireland’s tax authority on November 24 announced that it will extend the deadline for filing country-by-country reports of multinationals for fiscal years ending in 2016. The deadline has been extended from December 31 to February 28, 2018, due to technical difficulties associated with the electronic filing system. Irish Tax and Customs . . .
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G20
Countries lose significant revenue from multinational tax avoidance, OECD paper concludes
Multinationals, particularly the largest firms, take advantage of profit shifting to low tax rate countries, mismatches between country tax systems, and preferential tax regimes to significantly lower their tax bills, though countries that strengthen their antiavoidance laws may be able . . .
Asia-Pacific
Hong Kong to implement parent-surrogate country-by-country tax reporting for multinationals
Hong Kong’s Inland Revenue Department on December 22 issued more guidance on country-by-country reporting for large multinationals, including . . .
Africa
BRICS country tax officials express support for “inclusive framework” on BEPS
Heads of revenue of the BRICS countries – Brazil, Russia, India, China, and South Africa – at a meeting held December 5–6 in Mumbai, expressed support for measures . . .
Americas
Proposed debt/equity tax regs need revision, Democrat and Republican lawmakers say
In separate letters, US House Ways and Means Committee Republicans and Democrats have expressed concerns about proposed tax regulations issued last April that recharacterize some cross-border loans . . .
Council of the EU
EU ministers still can’t agree on anti-tax avoidance directive targeting multinationals
EU finance ministers at a June 17 ECOFIN meeting were again unable to reach political agreement on an anti-tax avoidance directive aimed at multinational corporations . . .
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Djibouti joins ‘Inclusive Framework on BEPS’ to fight tax avoidance
The OECD today announced that Djibouti has pledged to work alongside other nations on the continuing the work of the OECD/G20 base erosion profit . . .
Estonia
Ireland-Estonia treaty now exempts some royalty payments from tax
The tax treatment of royalty payments under the Ireland-Estonia tax treaty has been revised on account of the treaty’s most favored nation clause, Irish . . .
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EU court asked if Dutch can deny foreign fund dividend withholding tax refund
The Dutch Supreme Court has asked the Court of Justice of the European Union to resolve two separate disputes concerning whether the Netherlands can deny foreign investment funds refunds of the Dutch dividend withholding . . .
