The US IRS on August 28 released IRS agent training materials on transfer pricing rules under section 482 and on foreign-to-foreign transactions under . . .
China’s State Administration of Taxation in a June 23 English-language release described follow up procedures implementing the SAT’s decision no longer require tax administration approval . . .
The European Parliament’s Legal Affairs committee, on May 7, backed a draft law that would require large firms and public-interest entities to publicly report information on a country by country basis, with a goal of strengthening transparency of tax strategies . . .
The European Commission on February 18 announced that it will present a tax transparency package in March which will include a legislative proposal for the automatic exchange of information on tax . . .
Hong Kong’s Inland Revenue Department, on January 29, released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty . . .
Switzerland’s Federal Counsel. on April 30, announced that the government will prepare a consultation draft on corporate tax reform. The consultation will be based on a government report released December 2013 and will last until September 2014 . See, Press Release.
US lawmaker, Rep. Mark Pocan (D-WI), introduced two tax bills November 9 designed to take away tax benefits of corporate inversions . . .
The European Commission on September 28 published its annual overview of recent tax reforms . . .
The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.
The OECD has asked transfer pricing officers in multinational enterprises to participate in an online survey on transfer pricing comparability data . . .
The US Senate Finance Committee on April 30 released comment letters submitted to Senate working groups that are currently analyzing US tax reform options. The comments were submitted in . . .
The UK’s HM Revenue and Customs, on March 30, released interim guidance on its new diverted profits tax, set to go into effect April 1. The guidance uses practical examples to explain . . .
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
The European Commission, in a July 24 website post, announced it has extended the deadline for submitting applications to serve as a VAT Expert Group member until Sept. 12. Website, Call for Applications (22KB), Prior coverage.
Christian Aid on June 9 called the G7 leaders support for mandatory binding arbitration for multinational tax disputes “deeply troubling,” stating that the mechanism could further harm poor countries . . .
Ireland’s Tax and Duty Manual has been updated with expanded information regarding the procedures that migrating companies should use to elect to defer their exit charge under the tax laws, Irish Tax and Customs announced on May 26. See, Revenue eBrief No. 53/15.
The US on October 29 released seven international practice units. . .
Thailand’s Cabinet on May 7 approved a draft act introducing new transfer pricing provisions, including documentation requirements, writes PwC in a May 18 report. For details, see PwC.
The US IRS on May 6 issued two revenue rulings that conclude that transactions amount to section 351 transactions followed by D reorganizations . . .
UK clothing retailer Next owes additional £22.4m tax after a First-Tier Tribunal ruled the firm’s tax avoidance structure known as a rate-booster was artificial tax avoidance, the UK’ s . . .
The US IRS on April 3 issued final, temporary, and proposed regulations relating to the allocation of the credit for increasing research activities to corporations and trades or businesses under common control. See, TD 9717, REG-133489-13.
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) and Ranking Member Ron Wyden (D-Ore.) have requested stakeholder input on US tax reform, including international tax reform. The goal is to provide input for five bipartisan Finance Committee working groups that . . .
The UK on May 28 released a tax information and impact note on UK regulations issued March 11 that amend the worldwide debt cap. the regulations prevent changes to accounting standards from disallowing certain financing costs for investment entities. See, Corporation tax: changes to the worldwide debt cap (WWDC) provisions.
The Business Roundtable, an association of US company CEOs, on March 11 released a PWC report it commissioned which concludes that the US’s high tax rate coupled with its worldwide system of taxation disadvantages US businesses in the global cross-border mergers and acquisitions market, leading to foreign takeover of US businesses . . .
China’s State Administration of Taxation (SAT) on July 22 released an English-language translation of a June 3 announcement describing new policies . . .
ndia’s Committee on Direct Taxes on May 26 requested that stakeholders submit written comments on the issue of whether the government should impose minimum alternate tax (MAT) on gains of foreign financial institutions (FFIs) that arose prior to April 1. The committee, headed by Justice A.P. Shah, former. . .
Hong Kong’s Treasury Branch on April 24 launched a consultation on the legislative regime and operational framework for implementing automatic exchange . . .
Staff of the OECD, UN, IMF, and World Bank on November 6 released a report Options for Low Incomes Countries’ Effective and Efficient Use of Tax Incentives for Investment. The report was prepared at the request of the G20 Development Working Group. See: Report.
The UK’s HMRC on January 30 published a consultation paper entitled “Strengthening Sanctions for Tax Avoidance,” setting out proposals to address the serial use of tax avoidance schemes and proposing to introduce additional penalties . . .
China and South Korea have signed a bilateral advance pricing agreement, the Chinese goverment announced in a June 23 English-language release. The signing took place during a Sino-South Korea tax commissioners meeting . . .
Irish Tax and Customs on January 30 released guidance on qualifying avoidance disclosures under Section 811A(2A) Taxes Consolidation Act 1997. Under the
. . .
Australia’s Inspector General of Taxation, Ali Noroozi, on June 2, released a comprehensive report on the Australian Taxation Office’s (ATO) management of transfer pricing matters. The document is dated December 2013. Report (PDF 2.9 MB)
The US IRS today released to the public two more international practice . . .
Russia will not increase tax rates or the fiscal burden on business for four years, said Russian President Vladimir Putin according to a June 19 report in TASS. Putin also said Russia will take steps to increase the transparency . . .
Of the 201 CEOs that make up the membership of the Business Roundtable, 111 lead US companies that use offshore tax havens, and many lead companies that pay little or no corporate tax despite being profitable, according to a report by ranking member of the US Senate Budget Committee, Bernie Sanders (I-Vt.), released . . .
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