Multinational

Americas

Cayman Island guidance released on economic substance

May 16, 2019

The Cayman Islands government on April 30 . . .

Africa

Eswatini becomes the 132nd country to join the “Inclusive Framework on BEPS”

July 29, 2019

The OECD on July 26 announced the that southern Africa . . .

Africa

OECD seeks input on tax dispute resolution in Andorra, Anguilla, Bahamas, Bermuda, BVI, Cayman, Faroe Islands, Macau, Morocco, Tunisia

July 17, 2019

The OECD on July 5 requested taxpayer feedback on the tax treaty dispute . . .

Digital Economy

UN tax committee releases report on discussion and conclusions reached at eighteenth session: United Nations→

June 17, 2019

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OECD study suggests automatic exchange of information reduced bank deposits in offshore financial centers

June 7, 2019

Preliminary findings of an upcoming OECD study show that automatic exchange of information has reduced cross-border bank deposits in 46 international . . .

Featured News

OECD publishes work plan for sweeping international tax reform

May 31, 2019

As expected, the OECD today published a work plan setting out a process for reaching global consensus on revised rules for taxing multinationals. This key document had been agreed to by the 129-country . . .

Asia-Pacific

Synthesized text of Australia-Singapore tax treaty published: Australian Taxation Office→

May 25, 2019

Europe

Ireland should “engage constructively” on digitalization, tax avoidance to safeguard reputation, IMF says: International Monetary Fund→

May 14, 2019

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Featured News

OECD discussion draft on transfer pricing for financial transactions avoids key issues

July 19, 2018

Julian Feiner of Dentons, London, analyzes the OECD’s July 3 discussion draft on the transfer pricing aspects of financial transactions, highlighting three issues that warrant further consideration …

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OECD releases 2017 model tax treaty

April 24, 2019

The OECD today released the full version of the 2017 edition of the OECD Model Tax Convention . . .

Americas

Grenada joins “Inclusive Framework on BEPS” to fight multinational group tax avoidance

October 26, 2018

Grenada has joined the “Inclusive Framework on BEPS,” becoming the . . .

Americas

US FDII rules under review as potentially harmful tax regime, Treasury official says

February 19, 2019

The US’s foreign-derived intangibles income (FDII) tax rules are being scrutinized by the OECD’s Forum on Harmful Tax. . .

Featured News

Countries make headway on country-by-country reporting

May 25, 2018

An OECD report released May 24 found that 60 out of 95 countries reviewed have adopted final legislation to require multinationals to file country-by-country reports consistent with . . .

Americas

OECD, EU require Barbados to remove ring-fenced international tax regimes by December 31, Prime Minister says: Katrina King / Barbados Today→

August 27, 2018

Digital Economy

UN won’t wait for OECD action to tackle digital economy taxation

May 21, 2018

The UN Committee of Experts on International Cooperation in Tax Matters will not wait for the OECD to reach final conclusions on the taxation . . .

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UN publishes tax committee working methods and practices

May 7, 2019

The UN today published a document outlining the practices and working methods . . .

Danish tax law denying cross-border loss relief is invalid, EU court rules

June 18, 2018

Davide Anghileri of the University of Lausanne discusses a June 12 decision of the EU Court of Justice which concludes that a Danish law that precludes the deductibility of final losses incurred by a foreign permanent establishment violates EU law . . .

Featured News

UN tax committee releases draft transfer pricing chapter on financial transactions, other docs ahead of meeting (Updated)

April 10, 2019

The UN has released draft updates to the United Nations Practical Manual on Transfer Pricing for Developing Countries — including a key chapter on financial transactions — and more . . .

Americas

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

February 19, 2019

The OECD today asked multinational taxpayers and their advisors to provide information about their experiences with the tax treaty . . .

Asia-Pacific

Israeli transfer pricing guidance addresses low-interest loans

October 4, 2018

Jacky Houlie and Shlomo Hubscher of JH & Co. Law Office, Tel Aviv-Yafo, Israel, discuss a new circular produced by the Israeli tax authorities addressing transfer pricing aspects of low-interest domestic loans . . .

Africa

Mauritius signs MLI to combat multinational tax avoidance

July 5, 2017

As expected, Mauritius today signed the the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). If ratified, Mauritius’ action . . .

Europe

Spain applies MLI to 86 tax treaties, opts for mandatory binding arbitration: EY→

June 15, 2017

Multinational

Countries imposing new nexus rules to tax nonresident enterprises, resetting source v. residence: Gary D. Sprague / Bloomberg BNA→

February 15, 2017

See: Bloomberg BNA.

Europe

Netherlands deposits MLI ratification instrument with OECD after opting out of PE rule

April 1, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. note that the Netherlands on March 29 deposited its instrument of ratification of the BEPS MLI with the OECD and discuss the clauses that the Netherlands opted to adopt . . .

Featured News

OECD extends comment deadline for international tax consultation on digitalization

February 19, 2019

The OECD today announced that the deadline to provide public . . .

International Monetary Fund

IMF paper surveys tax avoidance via transfer mispricing, debt shifting, treaty shopping, tax deferral, corporate inversions; assesses effects on countries; notes research blind spots: Ruud de Mooij / International Monetary Fund→

January 28, 2019

Digital Economy

UN Committee of Experts meets to advance international tax and transfer pricing agenda

October 24, 2018

MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne, discusses the Committee of Experts on International Cooperation in Tax Matters seventeenth session, held in Geneva on October 16–19 . . .

Asia-Pacific

UAE joins “Inclusive Framework on BEPS”

May 16, 2018

The OECD today announced that the United Arab Emirates has become the 116th jurisdiction to join the . . .

Featured News

OECD may design short-term tax fix for digital economy, official says

October 18, 2017

An OECD interim report on tax implications of the digitization of the economy, promised for April 2018, may include discussion of temporary, short-term, tax measures, such as a turnover tax, an OECD official said October 17. Speaking during an OECD . . .

G20

OECD reports to G20 leaders on status of international tax agenda, tax transparency: OECD Secretary-General→

July 5, 2017

Featured News

The lack of transfer pricing comparables: selecting the appropriate box of apples in which to find bananas

March 16, 2017

Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .

Americas

British Virgin Islands set to join OECD Inclusive Framework on BEPS

December 19, 2016

The British Virgin Islands will join the OECD/G20 Inclusive Framework, pledging to adopt and work toward the implementation of the minimum international tax standards in the OECD/G20 Base Erosion Profit Shifting . . .

Multinational

OECD appoints EY’s VanderWolk to lead tax treaties, transfer pricing, financial transactions division

June 2, 2016

The OECD on June 2 announced that Jefferson VanderWolk will take over as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division at the Centre for Tax Policy and Administration (CPTA) in . . .

Featured News

Countries that accept BEPS minimum standards may participate in global tax effort, OECD says

February 23, 2016

Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according . . .

Featured News

Countries approve OECD proposal on VAT/GST collection by digital platforms

March 25, 2019

MNE Tax contributing editor, Davide Anghileri of the University of Lausanne, discusses the fifth Global Forum on VAT meeting in Melbourne, held March 20-22, where more than 100 jurisdictions, endorsed an OECD report on the role of digital platforms in the collection of VAT/GST on online sales . . ..

Digital Economy

Part one: OECD tax consultation on digitalization features 50+ speakers, diverse viewpoints (pillar one)

March 21, 2019

More than 50 international tax and transfer pricing experts from business, academia, labor, and non-governmental organizations spoke at a March 13–14 consultation, held at the OECD in Paris, on the tax challenges of digitalization. This article addresses the first day of the consultation which concerned the “pillar one” policy proposals . . .

Multinational

Report alleges that four large drug companies allocate profits to tax havens to avoid tax: Oxfam→

September 23, 2018

Multinational

Professors explore how MNEs shift risk among affiliates to move profits to low-tax countries: Johannes Becker, Niels Johannesen, Nadine Riedel→

May 21, 2018

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin