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More News

Asia-Pacific

Australia issues guidelines for simplified transfer pricing record-keeping

February 23, 2017

The Australian Taxation Office (ATO), on 22 February, released Practical Compliance Guideline PCG 2017/2 (PCG 2017/2), outlining simplified transfer pricing record-keeping options to minimise record-keeping for eligible taxpayers, writes Davide Anghileri . . . 

Americas

Trump’s tax plan calls for deemed repatriation of overseas profits

September 15, 2016

US presidential candidate Donald Trump’s revamped tax plan, unveiled today, reiterates his earlier call for a deemed repatriation of all corporate profits held offshore at . . . 

Americas

US IRS finalizes anti-loss importation tax regulations

March 28, 2016

The US IRS today published in the Federal Register final anti-loss importation regulations, making mostly minor changes from tax proposed regulations . . .

Americas

US IRS to step up scrutiny of transfer pricing involving foreign captive service providers

April 16, 2019

The US IRS’s Large Business and International division (LB&I) today announced a new . . .

Algeria

Spain appeals EU General Court’s finding of State aid in goodwill tax scheme 

March 28, 2019

Spain has appealed to the Court of Justice of the European Union seeking to overturn judgments . . .

Americas

Tax lawyer Jeffrey Tate Joins Arent Fox

December 18, 2018

Arent Fox LLP has expanded its tax practice in Washington, DC with the addition . . .

No Picture
Europe

European Economic and Social Committee reports on efforts to tax digital economy

July 31, 2018

European Economic and Social Committee, in a report released July 30, recommended that the EU analyze the effect of any interim measures to tax the digital companies on investments, start-ups . . .

Africa

Irish Revenue updates frequently-asked-questions on country-by-country reporting for multinationals

May 6, 2018

Irish Revenue has added new Tax and Duty Manual, Part 38-03-21 providing answers to frequently asked questions on Ireland’s laws and regulations applicable to large multinationals on country-by-country . . .

Americas

OECD requests feedback on tax treaty dispute resolution in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, Portugal

November 24, 2017

The OECD on November 24 asked for taxpayer input to conduct stage 1 peer reviews of the tax dispute resolution processes in Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal. Taxpayers are . . .

Americas

US, Lithuania sign country-by-country report exchange agreement

September 14, 2017

The US and Lithuania have agreed to annually exchange country-by-country reports on the tax affairs of large multinational businesses, the IRS reported. . .

Africa

Botswana becomes 99th country to join BEPS inclusive framework

June 12, 2017

The OECD announced June 9 that Botswana has joined the “Inclusive Framework on BEPS,” becoming the framework’s 99th member. The . . .

Europe

Italy clarifies tax credit for R&D activities

May 8, 2017

The Italian Revenue Agency has released a new circular clarifying aspects of Italy’s tax credit regime for research and development activities notes Davide Anghileri of the University of Lausanne . . .

Asia-Pacific

India-Korea bilateral advance pricing agreements can include rollback, Indian tax board says

March 20, 2017

“Rollback” of a transfer pricing method to resolve disputes in previous open tax years is permitted for bilateral advance pricing. . . .

Asia-Pacific

Australia consults on signing of BEPS multilateral instrument 

December 21, 2016

Australia Treasury has released a discussion paper seeking comments on whether the government should sign . . .

Americas

Brazil, Guernsey, Jersey, Isle of Man, Latvia sign agreement for exchange of tax reports on multinationals

October 24, 2016

Brazil, Guernsey, Jersey, the Isle of Man, and Latvia have signed a multilateral agreement which sets out the parameters for the automatic exchange between tax administrations of country-by-country tax reports on . . .

Europe

BEPS MLI to alter Luxembourg tax treaties as of August 1

April 9, 2019

Luxembourg today deposited its instrument of ratification for the . . .

Asia-Pacific

Nepal, Bangladesh sign tax treaty: my Republic→

March 7, 2019
Americas

Japan, Bahamas tax treaty protocol ratified

November 14, 2018

The Japanese government on November 12 announced that a protocol to . . .

Europe

Jersey releases tax guidance on new substance requirement

November 7, 2018

Jersey today released a document providing further details on the operation of a draft law that . . .

Asia-Pacific

Japan’s tax treaties with Australia, Slovakia, and France to be altered by BEPS MLI

October 2, 2018

The Japanese government today announced that its tax treaties with Australia, Slovakia, and France have been modified because Japan and these partners have now ratified a multilateral . . .

Americas

US IRS releases new advance pricing agreement template

May 16, 2018

The US IRS on May 11 released a new template for taxpayers to use when requesting an advance pricing agreement (APA), which is . . .

Asia-Pacific

Australian tax office planning release of thin cap guidance

March 1, 2018

The Australian taxation office (ATO) has announced that it intends to soon complete five guidance projects on Australia’s thin capitalization regime. In a February 28 update, the ATO advised that it . . .

No Picture
Europe

EU Commission launches consultation on digital firm taxation

October 26, 2017

The European Commission today launched a public consultation requesting public input how to rework the international tax rules so digital firms rare taxed in a fair and growth-friendly way. The Commission is working on new proposals on digital taxation . . .

Americas

US signs agreements with Czech Republic, Finland, Greece, Italy, and Sweden to exchange country-by-country reports

October 5, 2017

The US IRS announced this week that it has signed separate agreements with the Czech Republic, Finland, Greece, Italy, and Sweden to exchange country-by-country reports on multinationals. The bilateral competent authority agreements would help put into . . .

Americas

Canada Federal budget 2017 proposes base erosion rule for foreign branches of life insurers

March 22, 2017

Canada’s Federal budget 2017, released today, proposes to amend the Income Tax Act to prevent income from the insurance of Canadian risks from being shifted to a foreign branch of a Canadian life insurer . . . 

Americas

Panama joins BEPS inclusive framework

November 3, 2016

The OECD has today announced that Panama has become the 87th member of the “inclusive framework on BEPS,” which is a group of countries . . .

Europe

Ireland eases process to claim withholding tax exemption for patent royalties paid for nonresident companies

October 24, 2016

Irish Tax and Customs has amended its tax guidance to make it easier for companies to an claim an exemption from withholding for . . .

More News

OECD releases comments to draft dealing with banks and insurance companies that take excessive interest deductions

September 15, 2016

The OECD on September 15 released 27 comment letters responding to a discussion draft designed to assist countries that seek to prevent multinational banks and insurance companies from . . .

Europe

Guernsey ratifies multilateral tax treaty aimed at closing MNE tax loopholes

February 12, 2019

Today, Guernsey became the 20th jurisdiction to deposit with the OECD its instrument of ratification for . . .

Americas

US, Indonesia negotiating exchange of country-by-country tax reports

April 18, 2018

The US IRS on April 17 announced that it has entered into negotiations with Indonesian tax authorities for the exchange of country-by-country tax reports on multinational . . .

Americas

OECD publishes updated transfer pricing profiles for 14 countries

April 9, 2018

The OECD today published transfer pricing profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay. The profiles

Asia-Pacific

New Zealand tax bill hits interest deduction, hybrid mismatches, PEs, transfer pricing

December 6, 2017

A tax bill to counter tax avoidance by multinational companies was introduced into New Zealand’s Parliament today. The government also released its commentary on the bill, prepared by Stuart Nash, New Zealand’s Minister . . .

Americas

Trinidad and Tobago joins “inclusive framework on BEPS” to combat multinational tax avoidance

November 24, 2017

The republic of Trinidad and Tobago has joined the “inclusive framework on BEPS,” a group of countries that have pledged to implement measures aimed at preventing tax avoidance and improving tax dispute resolution set out in the 2015 OECD/G20 base erosion profit shifting (BEPS) . . .

OECD
More News

OECD releases comments to draft model tax treaty provisions

August 14, 2017

The OECD has released seven comment letters responding to draft revisions to the OECD model tax convention. The revisions are to be included in a . . .

Europe

UK country-by-country reporting guidance published

March 30, 2017

The UK’s HM Revenue & Customs (HMRC) today published a policy paper titled “Amendments to Country By Country reporting 2017” and an updated policy. . .

Asia-Pacific

Updated Singapore transfer pricing guidance allows simplified method for related party loans

January 12, 2017

Singapore’s Inland Revenue Authority (IRAS) on January 12 published the fourth edition of its e-Tax Guide on transfer pricing. The new guidance includes a discussion . . .

Americas

US IRS seeks feedback on transfer pricing documentation regs

February 28, 2019

The US IRS, in a February 26 notice, has solicited feedback on whether taxpayer burdens imposed by tax regulations governing transfer pricing . . .

Asia-Pacific

Japan-Ireland tax treaty to be modified by MLI

February 11, 2019

The Japanese government on February 8 announced that a 1974 bilateral tax treaty between Japan and Ireland . . .

Americas

Country-by-country reporting exchange agreement between US and Slovenia available

June 15, 2018

The US IRS today made available on its website a country-by-country reporting exchange . . .

Posts navigation

« 1 … 14 15 16 … 25 »

What’s Next

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May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.