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More News

Europe

Ireland releases Q&As on country-by-country reporting for multinationals

December 13, 2016

Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .

Europe

EU Commission survey addresses tax advisors, intermediaries that aid tax evasion and avoidance

November 10, 2016

The European Commission has today launched a public consultation on whether the EU should take action to create disincentives for tax advisors and other intermediaries that help taxpayers . . .

Andorra

Andorra becomes 40th non-OECD/G20 country to join “inclusive framework” for BEPS implementation 

October 19, 2016

Andorra has become the 40th country that is neither an OECD nor G20 member to join what is known as the inclusive framework for BEPS implementation, a group of countries that have pledged to adopt measures, designed by the OECD and G20 in the base. . .

Asia-Pacific

Singapore issues country-by-country reporting guide assist MNEs

October 12, 2016

Singapore’s tax authority has prepared a tax guide addressing how large multinationals can fulfill the obligation to prepare and submit country-by-county reports . . .

Asia-Pacific

Novo Nordisk becomes first pharmaceutical to sign bilateral APA with China

February 28, 2019

Novo Nordisk has concluded a bilateral advance pricing agreement (APA) with the Chinese tax . . .

Europe

UK, Isle of Man tax treaty enters into force

January 7, 2019

A new tax treaty between the Isle of Man and the UK entered into force today, the . . .

Asia-Pacific

Australia focusing on pharmaceutical industry tax, transfer pricing practices

September 8, 2017

The Australian Taxation Office (ATO) announced September 7 that it is conducting an in-depth review the tax and transfer pricing practices of the pharmaceutical industry to make sure that the correct amount of tax . . .

Americas

US, Canada sign competent authority agreement for exchange country-by-country tax reports

June 19, 2017

Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . . 

More News

New Zealand issues withholding tax rules for interest paid to related foreign lenders

April 12, 2017

New Zealand’s Inland Revenue on April 11 issued a special report providing guidance on new withholding tax rules for interest paid to related-party foreign lenders. Changes to these rules were made in the . . . 

Africa

Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance

November 26, 2016

Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .

More News

OECD releases 14 comments letters on conforming amendments to transfer pricing guidance

August 24, 2016

The OECD on August 24 released letters from 14 organizations responding to its request for comments on draft conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines titled
. . .

Europe

Ireland ratifies BEPS MLI to fight MNE tax avoidance

January 29, 2019

Today, Ireland deposited its instrument of ratification for the multilateral . . .

Asia-Pacific

Australia updates transfer pricing guidance for offshore hubs

October 16, 2018

The Australian Taxation Office (ATO) on October 11 updated its transfer pricing guidance . . .

Asia-Pacific

Israel, Lithuania ratify BEPS multilateral convention

September 13, 2018

Israel and Lithuania have ratified a multilateral tax treaty designed to curtail tax avoidance by multinational groups . . .

More News

Draft “toolkit” for developing countries addresses mining tax incentives

June 18, 2018

A new draft “toolkit” for developing countries, released today, addresses tax incentives used by the developing countries designed to attract foreign and . . .

Americas

Qatar, Saint Kitts and Nevis join inclusive framework on BEPS

November 14, 2017

Qatar and Saint Kitts and Nevis have joined the inclusive framework on BEPS, bringing total membership to 106 countries, the OECD announced November 14. The inclusive . . .

Asia-Pacific

Vietnam becomes 100th member of “BEPS framework” to fight tax avoidance

June 21, 2017

The OECD on June 21 announced that Vietnam has pledged to work alongside other nations on the continuing the work of the OECD/G20 base erosion . . .

Asia-Pacific

Australia hits multinationals with large tax bills using new anti-avoidance law

April 7, 2017

Australia has assessed seven multinational corporations with tax liabilities totaling AUS $2.9 billion (~USD 2.2 billion), Treasurer Scott Morrison and Minister . . .

Asia-Pacific

Taiwan offers VAT refund to some foreign enterprises without fixed place of business

March 14, 2017

Taiwan’s taxation office announced Monday that foreign enterprises and other entities from specified countries that have no fixed place of business in Taiwan but engage in. . . 

Americas

US IRS issues final reporting, record keeping rules for foreign-owned disregarded domestic entities

December 13, 2016

The US IRS on December 13 published final tax regulations (T.D. 9796) under sections 6038A and 7701 that require wholly foreign-owned domestic disregarded entities to be treated as a domestic corporations, separate from their owners . . .

Asia-Pacific

Singapore releases tax form for reporting related party transactions

November 3, 2016

Singapore’s Inland Revenue Service has today released a sample copy of tax form to be used by multinationals to report related party transactions. The form is designed to allow the tax agency to better assess transfer pricing . . .

Asia-Pacific

Australia reviewing its research and development tax incentive

September 29, 2016

The Australian government on September 28 released a draft report suggesting ways to improve the country’s research and development (R&D) tax incentive . . .

Europe

Ireland updates tax guidance on capital allowances for intangibles

April 24, 2019

Irish Tax and Customs on April 18 updated its tax and duty manual to reflect changes . . .

Europe

Finland deposits BEPS MLI acceptance instrument with OECD

February 25, 2019

Finland today deposited with the OECD its instrument of acceptance of a multilateral treaty . . .

More News

OECD/IGF final reports address BEPS tax avoidance in mining sector

October 22, 2018

The OECD’s Centre for Tax Policy and Administration and the IGF, a group of about 60 countries that are also UN members, on October 19, released three final practice notes addressing tax . . .

Asia-Pacific

India extends comment due date for “significant economic presence” rule for taxing MNEs

August 30, 2018

The Indian government today announced that it has extended the due date for public comment on its newly adopted “significant economic presence” test, a nexus rule designed to expand India’s taxation rights . . .

No Picture
Europe

Dutch tax law denying nonresidents tax advantage of integration is illegal, ECJ Advocate General says 

October 25, 2017

Applying the Court of Justice of European Union decision in Groupe Steria, Advocate General Campos Sanchez-Bordona today gave his opinion on two aspects of Dutch tax law in joined cases, X BV, case C‑398/16; and X NV, case C‑399/16. The Advocate General . . .

Africa

Cameroon signs MLI to tackle tax avoidance by multinational enterprises

July 11, 2017

Cameroon’s Minister of Finance, Alamine Ousmane Mey, today signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and . . .

Europe

Italy: Google to pay 306 million euros to settle tax dispute

May 4, 2017

Google has settled a tax dispute in Italy, writes Davide Anghileri of the University of Lausanne  . . .

Americas

US Democrats introduce bill to close foreign reinsurance tax loophole

September 29, 2016

US Democrats on Wednesday introduced a bill designed to prevent foreign insurance groups from avoiding US tax by paying reinsurance premiums to affiliates located in tax . . . 

Europe

Ireland’s tax authority issues FAQs on country-by-country reporting

June 23, 2016

Irish Revenue on June 23 issued a set of frequently asked questions regarding new Irish tax legislation and regulations that require country-by-country reporting by . . .

Europe

UK’s HMRC details new requirement for large businesses to publish tax strategy

March 31, 2016

The UK’s HM Revenue and Customs (HMRC) on March 31 published draft guidance describing new rules that will require large companies, partnerships . . .

More News

US IRS issues regulations on partnership allocations of creditable foreign tax expenditures

February 4, 2016

The IRS on Wednesday released final, temporary, and proposed regulations applicable to partnerships that claim the foreign tax credit for foreign income taxes. The regulations. effective February 4, clarify aspects of the section 1.704-1(b)(4)(viii) safe harbor rule that allows allocations of. . . 

Americas

Belize signs and Monaco ratifies BEPS mulitlateral tax treaty

January 13, 2019

The OECD on January 11 announced that . . .

Americas

Bermuda updates country-by-country reporting guidance for large MNEs

August 10, 2018

Bermuda’s government has released an updated version of its guidance notes for large multinationals on country-by-country reporting. The guidance . . .

Americas

US IRS clarifies instructions for country-by-country reporting forms

July 25, 2018

The US IRS today issued clarifications to the instructions for filing Schedule A (Form 8975) dealing with country-by-country reporting for multinationals. The new instructions detail . . .

Asia-Pacific

UK proposes to change to BEPS MLI reservations and notifications

April 16, 2018

The UK government today announced proposed changes to the provisional reservations and notifications it made when it signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent . . .

Asia-Pacific

Taiwan clarifies transfer pricing documentation rules for companies that undergo merger, acquisition, accounting change

April 3, 2018

Taiwan’s government on April 1 clarified how multinational enterprises should compute transfer pricing documentation thresholds when they operate in Taiwan for less than a full year due to merger, acquisition, or change to fiscal year-end. The National Taxation . . .

Asia-Pacific

OECD publishes reports covering cross-border tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

March 13, 2018

The OECD today published reports approved by the “Inclusive Framework on BEPS” which assess tax dispute resolution practices in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain. As members . . .

Posts navigation

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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

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • 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
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021

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