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More News

More News

OECD publishes updated manual on preventing BEPS through interest deduction limits

December 22, 2016

The OECD on December 22 published a report on limiting base erosion involving interest deductions and other financial payments, updating . . .

More News

OECD surveys business about need for tax certainty

October 18, 2016

The OECD today invited business representatives to respond to a survey on how tax certainty promotes . . .

Africa

Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance

July 19, 2016

Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .

Americas

US Tax Court releases decision in Illinois Tool Works repatriation case

August 7, 2018

The US Tax Court on August 6 released its decision in Illinois Tool Works, sanctioning a US MNE’s strategy to repatriate foreign earnings held by . . .

Americas

US, Indonesia agree to exchange country-by-country data on multinationals to prevent tax avoidance

July 2, 2018

The US and Indonesia have signed a competent authority agreement providing for the exchange of country-by-country reporting data, US Treasury . . .

Americas

Saint Lucia becomes 114th country to join “inclusive framework” countering multinational tax avoidance

May 9, 2018

The OECD has announced that Saint Lucia has joined the “Inclusive Framework on BEPS,” bringing the number of participating countries to 114. The OECD-led framework . . .

Americas

US, Cayman Islands negotiating exchange of country-by-country reports on large multinationals

February 27, 2018

The US and the Cayman Islands are negotiating competent authority agreement for the bilateral exchange of country-by-country reports on large multinationals, the US IRS announced . . .

Americas

US IRS to deny accounting period changes that avoid tax on deemed repatriation

February 13, 2018

The US IRS today announced it will deny a change in the accounting period of some US companies’ foreign affiliates if the change results in avoidance of the US’s newly enacted transition tax, which deems a repatriation of US company’s existing offshore earnings. Rev. Proc. 2018-17 prevents . . .

Africa

Draft South African guidance details tax rules denying deduction for royalty payment on “tainted” IP

January 9, 2018

The South African Revenue Authority on January 9 issued draft guidance interpreting a 2009 law which denies a tax deduction for royalties paid to use “tainted” intellectual . . .

Americas

US, Bermuda negotiating exchange of country-by-country tax reports on multinational firms

September 7, 2017

The US is negotiating with Bermuda to annually exchange country-by-country reports on large multinational businesses, the IRS said today. The exchange relates to a 2015 deal reached between nations resulting . . .

No Picture
Europe

EU Commission seeks public input on cooperation to prevent cross-border VAT fraud

March 2, 2017

The EU Commission today opened a public consultation to gather views on the functioning of administrative cooperation regarding value added tax (VAT) and regarding the fight. . . .

Europe

EU proposals for public country-by-country reporting, CCCTB should be rejected, Irish finance minister says

February 16, 2017

Ireland’s Minister for Finance Michael Noonan today expressed opposition to EU Commission proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country reporting, arguing that both measures are counterproductive . . .

Americas

Fight brewing over effort to roll back US debt/equity tax regulations

February 9, 2017

US Democrats on the House Ways and Means Committee today urged their colleagues to oppose an effort to repeal the final Section 385 debt/equity . . .

Americas

Bermuda, Kazakhstan, Côte d’Ivoire join BEPS group fighting cross-border tax avoidance

January 6, 2017

Bermuda, Kazakhstan, and Côte d’Ivoire have joined the “Inclusive Framework on BEPS,” to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . . 

Denmark

EU court to hear challenge to Denmark’s withholding tax on dividends paid to foreign investment funds

November 14, 2016

The European Court of Justice has published a reference for a Danish case (C-480/16) in the . . .

Asia-Pacific

Australia: country-by-country reporting exemption guidance offers relief to MNEs

October 18, 2016

The Australian Taxation Office (ATO) has issued guidance for multinational groups on how to apply for an exemption from the obligation to provide some or all of the information in required tax statements known as . . .

No Picture
Europe

EU Advocate General approves directive excluding digital publications supplied electronically from reduced VAT

September 13, 2016

The EU VAT Directive is valid in so far as it applies a reduced rate of tax only to printed books, newspapers and periodicals, as well as to digital books which are supplied by means of a physical medium, as opposed to digital publications supplied electronically . . .

No Picture
Austria

EU countries seek September compromise on financial transaction tax

June 20, 2016

Ten EU countries remain committed to a financial transaction tax, agreeing to a compromise plan offered by Austria and setting September as the final date to iron out differences, reported Austrian Minister of Finance. . . .

Europe

UK wins court case challenging Bank of Ireland tax scheme involving intragroup transfer of interest rate swaps

May 11, 2016

A Bank of Ireland subsidiary, Bristol & West (B&W), located in the UK, has lost its appeal in UK courts in a tax avoidance case that involved its novation of a portfolio of “in the money” interest-rate swaps . . .

Americas

Panama signs multilateral country-by-country reporting pact

January 31, 2019

Panama’s tax authorities on January 24 signed the . . .

Digital Economy

BIAC weighs in on digital tax debate

January 22, 2019

The OECD’s business forum (BIAC) today released . . .

Americas

Antigua and Barbuda, Dominica, Saint Vincent and the Grenadines join “Inclusive Framework on BEPS”

October 23, 2018

Antigua and Barbuda, Dominica, and Saint Vincent and the Grenadines have joined the “Inclusive Framework on BEPS,” a coalition of countries that have pledged to implement minimum standards on international taxation . . .

Africa

Australia releases draft law adopting BEPS MLI, seeks to amend 30 bilateral tax treaties 

February 8, 2018

The Australian government on February 8 released for public comment a draft law that would give the force of law to a multilateral tax treaty designed to amend about 30 of Australia’s tax treaties with other . . .

No Picture
Europe

EU court to hear Swedish case on application of Marks & Spencer to losses in subsidiary not directly owned by parent

January 9, 2018

The Court of Justice of the European Union January 8 published a reference from a Swedish court asking whether a parent company’s right to deduct definitive losses of a subsidiary based on the Marks & Spencer case is depended on the subsidiary being directly owned . . .

More News

OECD: peer review for BEPS minimum standards released

February 1, 2017

The OECD today released documents to implement peer review of countries’ compliance with minimum standards devised under OECD/G20 base erosion and profit shifting (BEPS) Action 13, dealing with country-by-country reporting, and . . . 

Europe

UK releases draft legislation to limit interest deductions of large corporations

December 6, 2016

The UK government, on December 5, published draft clauses for a tax law that will limit the interest deductions of large corporations, to be included in the 2017 . . . 

Americas

US group urges Congress to cut OECD funding, claims US harmed by BEPS international tax standards

May 18, 2016

Representatives about 20 US advocacy groups, in a May 12 letter, urged Congress to stop funding the OECD, arguing that its work developing worldwide standards to tax multinational . . .

Asia-Pacific

Hong Kong tax bill introduces temporary tax cuts

March 4, 2016

The Hong Kong government on March 4 published Inland Revenue (Amendment) (No. 2) Bill 2016, to implement the concessionary revenue measures proposed in the . . .

No Picture
Europe

EU seeks to improve cross-border business tax dispute resolution

February 16, 2016

The European Commission on February 16 launched a public consultation seeking feedback on ways to improve the resolution of double . . .

Asia-Pacific

Hong Kong, Finland tax treaty enters into force

January 7, 2019

A comprehensive tax treaty between Hong Kong and Finland entered into force . . .

Asia-Pacific

Denmark-Japan double tax treaty enters into force 

January 3, 2019

Michael Vorndran, a principal with Nord Advisory AS, Oslo, Norway, notes that a new tax treaty between Denmark and Japan has entered into force . . .

Europe

EU removes Namibia from tax blacklist

November 6, 2018

The EU Council today decided to further amend the EU blacklist of non-cooperative . . .

Americas

Bermuda, Curaçao, Hong Kong,  Liechtenstein update plans to exchange country-by-country reports on MNEs

September 13, 2018

The OECD today reported that Bermuda, Curaçao, Hong Kong, and Liechtenstein have announced new bilateral exchange relationships with other . . .

Africa

OECD publishes transfer pricing profiles for Costa Rica, Greece, South Korea, Panama, Seychelles, South Africa, Turkey, Singapore

September 7, 2018

The OECD today announced the release of new transfer pricing . . .

Africa

US agrees to exchange country-by-country tax reports with Liechtenstein and Mauritius

May 16, 2018

US IRS has announced that it has agreed to exchange country-by-country reports on large multinationals with Liechtenstein and Mauritius.

The agreement . . .

Americas

US IRS updates Q&As on country-by-country reporting to reflect national security exception

April 11, 2018

The US IRS on April 10 added two new entries to its Q&As that provide guidance to large multinationals that must file country-by-country reports on their tax affairs with the government. Both entries address the new national security exception to country-by-country guidance, discussed . . .

Africa

South Africa grants extension for multinationals to file country-by-country reports

December 2, 2017

The South African government has granted an extension for multinationals to file country-by-country reports originally due December 2017 or January 2018. MNE . . .

No Picture
Austria

Austrian, German dispute over taxation of profit-participation certificates to be considered by European Court

February 8, 2017

The European Court of Justice has published a reference for an Austrian case (Case C-648/15) concerning whether Austria or Germany can tax profit-participation certificates (Genussscheine). Austria claims that the Court should hold that . . .

Europe

Guidance on Northern Ireland’s corporate tax regime published

September 27, 2016

The UK tax authority on September 26 published draft guidance on the operation of Northern Ireland’s corporation tax regime, setting out . . .

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What’s Next

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May 19 – 20IFA Second European Region ConferenceMilan, Italy
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
  • 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
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 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.