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. . . .
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 . . .
The OECD today announced that Malaysia has joined the “Inclusive Framework on BEPS,” which is a group of countries that have pledged to implement tax measures to combat multinational tax avoidance designed by OECD and G20 countries in its . . . .
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 . . .
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 . . .
Multinationals, particularly the largest firms, take advantage of profit shifting to low tax rate countries, mismatches between country tax systems, and preferential tax regimes to significantly lower their tax bills, though countries that strengthen their antiavoidance laws may be able . . .
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 . . .
Davide Anghileri of the University of Lausanne writes about new guidance issued by the South African Revenue Service that identifies taxes that are similar to income taxes and thus qualify for tax treaty relief . . .
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 . . .
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 . . .
The US Internal Revenue Service has today published final and temporary (TD 9815) and proposed (REG-135122-16) tax regulations providing guidance to nonresident alien individuals and foreign corporations that hold financial products providing for payments. . .
The US IRS on January 19 issued temporary (TD 9811) and proposed (REG-127203-15) regulations that require US persons to recognize gain on the transfer of appreciated property in exchange for an interest in partnership which has foreign partners . . .
The US IRS on January 19 issued guidance providing a procedure for the ultimate parent entity of a US MNE group to voluntarily file Form 8975 for early reporting periods. The filing is required effectuate . . .