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Peer review of OECD and G20 countries shows mixed progress on exchange of private tax ruling information
The OECD today released peer reviews assessing whether 44 countries have met their commitments to disclose information to other countries about the private tax rulings they grant to multinational firms. The commitments, made as a part of 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements between . . .
Africa
Transfer pricing comparables “toolkit” reflects realities of developing nations, UN official says
A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18. Michael Lennard . . .
Multinational
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OECD details peer review plan for BEPS tax treaty abuse minimum standards
The OECD today outlined the peer review process to be used to assess countries’ compliance with minimum standards set out in the OECD/G20 base erosion profit shifting (BEPS) plan on tax . . .
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Business reacts to OECD group ratio rule for multinational corp interest deductions
The OECD on August 25 released 23 comment letters from business groups responding to its request for feedback on a discussion draft on the design of a group ratio rule. The group ratio rule would supplement OECD recommendations on how countries . . .
Americas
Asia-Pacific
Hong Kong joins BEPS project fight against multinational corp tax avoidance
Hong Kong will join countries involved in the next stage of the OECD/G20 base erosion profit shifting (BEPS) plan as an associate, adopting the BEPS minimum standards and participating in the . . .
Multinational
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The UN transfer pricing manual’s new chapter on financial transactions: the details
Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, offer a detailed analysis of the UN Committee of Experts on International Cooperation in Tax Matters’ April 8 a draft chapter on financial transactions, proposed as an update to the UN Practical Manual on Transfer Pricing for Developing Countries . . .
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Africa
OECD officials discuss international tax and transfer pricing agenda
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .
Multinational
Multinational
Cyprus
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New ‘toolkit’ addresses lack of transfer pricing comparables
The “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and the World Bank – today published the final version of a toolkit designed to provide developing . . .
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OECD officials provide update on international tax agenda
Tax officials, during a March 28 webcast, discussed the OECD’s international tax agenda, including plans to release tax and transfer pricing guidance and promote . . .
Americas
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Americas
Multinational
Americas
US planning international tax guidance on BEAT, GILTI, transition tax, Treasury official says
The US intends to issue proposed tax regulations next month addressing the section 965 transition tax followed by year-end guidance on the GILTI, BEAT, and other international tax provisions introduced in the 2017 Tax Cuts and Jobs Act, said Lafayette (Chip) G. Harter, Deputy Assistant Secretary (International Tax Affairs) at US Treasury during the 2018 OECD International Tax Conference, held . . .
Europe
EU Commission investigating UK controlled foreign corporation law for State aid violation
The European Commission has opened an in-depth State aid investigation into the UK’s controlled foreign company (CFC) tax laws applicable to multinationals, specifically, the CFC rules’ group financing exception. The group financing exception to the CFC rules, added in 2013, is applicable to multinationals . . .
Digital Economy
ASEAN
Europe
Europe
Europe
EU Parliament proposal would extend public country-by-country reporting to more multinationals
An EU Commission proposal to require public country-by-country reporting by multinationals operating in Europe should be extended to cover many more multinationals and to mandate much more robust . . .
Multinational
Alex Cobham to head Tax Justice Network
Alex Cobham will take over as executive director of the Tax Justice Network, the advocacy group . . .
Europe
Asia-Pacific
Pakistan signs multilateral agreement to fight tax evasion and avoidance
Pakistan today became the 104th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the . . .
Americas
US threatens to stop treating some FATCA IGAs as being “in effect” in 2017
Beginning in 2017, the US will stop treating a country as if it has FATCA intergovernmental agreement (IGA) “in effect” if the country does not adequately prove that it has a plan . . .
Americas
Countries targeted US companies in BEPS project to increase tax revenue, US Treasury official charges
Countries participating in the OECD/G20 base erosion profit shifting (BEPS) project sought to rewrite international tax rules for the digital economy and for intellectual property to increase their tax take at the expense of the United States, Robert Stack, Treasury deputy assistant secretary. . .
Multinational
Researcher analyzes the new BEPS plan principal purpose test for tax treaties: Andrés Báez / SSRN→
See: GAARs and Treaties. From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6? by Andrés Báez. Available at: SSRN
European Commission
