Multinational
EU Council approves new cross-border tax dispute resolution plan
As expected, the ECOFIN Council today approved a directive establishing a new system for resolving double taxation disputes between EU member states. The new directive on tax dispute resolution follows an agreement reached by EU nations on May 23. It was approved without discussion. Member states will have until June . . .
India confirms intent to sign BEPS multilateral instrument curbing tax avoidance
Mansi Seth and Afaan Arshad of Nishith Desai Associates discuss today’s announcement that the Indian Union Cabinet has approved India’s signing of the multilateral instrument (MLI) to implement the tax treaty measures in the OECD/G20 base erosion profit shifting (BEPS) action plan . . .
OECD officials outline international tax initiatives, country-by-country reporting guidance released
OECD officials, during a December 5 webcast, discussed OECD international tax work, including just-released guidance implementing country-by-country reporting standards, the G20’s tax agenda, the BEPS multilateral instrument, OECD drafts on profit splits . . .
OECD releases 28 comments to draft on tax treaty residence of pension funds
The OECD on April 6 released public comments to a discussion draft intended to clarify the tax treaty residence of pension funds. The discussion draft, part of follow-up work . . .
OECD report reveals disagreement on taxation of digital firms
A highly anticipated OECD interim report, published today, reveals that there is still no consensus among countries on whether changes should be made to international tax rules that apply to multinational digital firms. Countries did agree to study international tax concepts to see if improvements can be made, though. Also, while the report states that there is no consensus on short-term interim measures to tax the digital economy either, countries . . .
Comments released on tax guidance addressing offshore indirect asset transfers
18 comment letters – including letters from the governments of India and China — were released today responding to a draft “toolkit” designed to help developing countries address the taxation of offshore indirect transfers of assets, a practice used by some multinational corporations for tax avoidance. The guidance was prepared by “Platform for Collaboration on Tax,” a joint effort of the IMF, UN, OECD, and . . . .
Twenty nations’ tax laws may aid multinational profit shifting, OECD report says
Twenty countries have tax laws that may be considered harmful preferential regimes, facilitating tax avoidance by multinationals and reducing the tax base of other countries, an OECD report released Monday revealed. The review, conducted by the OECD Forum on Harmful Tax Practices (FHTP), assessed countries’ tax laws against . . . .
UN committee weighing major updates to model tax treaty, other guidance
The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . .
UAE signs multilateral treaty to fight offshore tax evasion and multinational corporation avoidance
The United Arab Emirates on April 21 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 109th jurisdiction to participate in the convention. The treaty, developed in 1988 by the OECD and the Council of Europe, would enable . . .
EU court to consider beneficial ownership definition for interest and royalty directive
The European Court of Justice (ECJ) on March 6 published a reference for a preliminary ruling in a Danish case (C-682/16) requesting guidance on the interpretation of the term “beneficial owner” in the context of the EU interest and royalty directive, writes Davide Anghileri of the University of Lausanne . . .