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Thailand becomes 98th country to join ‘Inclusive Framework on BEPS’ to combat multinational tax avoidance
The OECD today announced that Thailand has joined countries that have pledged to implement the OECD/G20 base erosion profit shifting (BEPS) plan minimum . . .
Europe
EU “hybrid mismatch” tax proposal advances
The European Parliament on April 27 adopted a legislative resolution on a proposal for a Council directive . . .
Asia-Pacific
Australia: draft tax ruling addresses central management and control test for tax residency
The Australian Taxation Office (ATO) has released a draft taxation ruling setting out the ATO’s view on when a foreign incorporated company is considered an Australian tax resident under the central management and control test, writes Davide Anghileri. . . .
Americas
US IRS releases updated foreign partnership, trust withholding agreements
The US IRS on January 20 released an updated withholding foreign partnership agreement (WP agreement) and withholding foreign trust agreement (WT agreement). The agreements, in . . .
Europe
Ireland adds time limits to bilateral advance pricing agreements but not other tax rulings
Irish Revenue has updated its tax manual to provide for strict time limits on the duration of bilateral advance pricing agreements (APAs) signed with other nations, but has declined to specify that any firm limits will be imposed on tax rulings granted to large taxpayers that seek confirmation of the tax treatment . . .
Asia-Pacific
India set to tax payments to nonresidents for online advertising as of June 1
India’s Central Board of Direct taxes today released a notice announcing details of a new 6 percent tax that will be imposed on payments made to nonresidents for online advertising beginningr . . .
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OECD releases 40 comments to consultation on tax treaty entitlement for non-CIV funds
The OECD on April 27 released comments from 40 organizations responding to a discussion draft on the tax treaty entitlement of non-CIV funds, such as private equity funds, pension funds . . .
Europe
Switzerland issues drafts rules on exchange of tax information with foreign governments
Switzerland’s Federal Council on April 20 launched a consultation on proposed revisions to rules on tax . . .
Americas
Bermuda signs agreement for exchange of country-by-country tax reports
Bermuda has become the 33rd signatory to a multilateral agreement setting out the parameters for the automatic exchange between tax administrations. . . .
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Council of the EU
Council expected to approve EU-wide tax dispute resolution system
The Economic and Financial Affairs Council is expected to approve a directive establishing an EU-wide system for resolving double taxation disputes at its meeting of October 10. Ministers will also hear a presentation by the Commission about its proposed strategy for digital taxation, aimed at . . .
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Lebanon, Kuwait, Turkey sign international tax agreements
Lebanon and Kuwait have signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, bringing total signatories to the agreement. . .
Africa
Russia, Malta, Mauritius, Hungary, Gabon, Indonesia, Lithuania sign tax agreement on exchange of country-by-country reports
In an effort to provide their tax administrations with tools to combat corporate tax avoidance through transfer pricing, officials from 7 more countries have signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large . . .
Americas
US IRS issues final and proposed tax regulations on US property held by CFCs involving partnerships
The US IRS today published final regulations (TD 9792) providing rules regarding US property held by a controlled foreign corporation (CFC) in connection with certain transactions . . .
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OECD proposes conforming amendments to transfer pricing guidelines on business restructuring
The OECD on July 4 published proposed amendments to Chapter IX of the transfer pricing guidelines dealing with business restructuring to conform the guidance to recent changes made to other chapters on account. . .
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Australia budget 2017 hits hybrid regulatory capital tax abuse, extends MAAL
In a further effort to curtail tax avoidance by multinationals, Australia will introduce hybrid mismatch provisions applicable to banks and insurance companies and tighten . . .
Americas
Cayman Islands, Belize to adopt BEPS international tax standards
The Cayman Islands and Belize have become members of the “Inclusive Framework on BEPS,” the OECD announced today. The inclusive framework is a group of countries that have pledged to put into place minimum standards aimed at preventing tax avoidance and improving . . .
Americas
US finalizes regs on outbound transfers of foreign goodwill
The US IRS has released final regulations (TD 9803) under section 367 which eliminate the favorable tax treatment of outbound transfers . . .
