Multinational
Thailand becomes 98th country to join ‘Inclusive Framework on BEPS’ to combat multinational tax avoidance
The OECD today announced that Thailand has joined countries that have pledged to implement the OECD/G20 base erosion profit shifting (BEPS) plan minimum . . .
EU “hybrid mismatch” tax proposal advances
The European Parliament on April 27 adopted a legislative resolution on a proposal for a Council directive . . .
EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
OECD releases 40 comments to consultation on tax treaty entitlement for non-CIV funds
The OECD on April 27 released comments from 40 organizations responding to a discussion draft on the tax treaty entitlement of non-CIV funds, such as private equity funds, pension funds . . .
Lebanon, Kuwait, Turkey sign international tax agreements
Lebanon and Kuwait have signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, bringing total signatories to the agreement. . .
Cyprus to sign OECD multilateral treaty on tax avoidance, dispute resolution
Cyprus will sign the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting( MLI), Cyprus’s Ministry of Finance has announced . . .
Russia, Malta, Mauritius, Hungary, Gabon, Indonesia, Lithuania sign tax agreement on exchange of country-by-country reports
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 . . .
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
OECD proposes conforming amendments to transfer pricing guidelines on business restructuring
The OECD on July 4 published proposed amendments to Chapter IX of the transfer pricing guidelines dealing with business restructuring to conform the guidance to recent changes made to other chapters on account. . .
Transfer pricing guidelines should be interpreted consistently with BEPS changes, OECD says
Countries that integrate the OECD transfer pricing guidelines into their national laws should now begin to apply not only the recently approved OECD/G20 base erosion profit shifting (BEPS) plan transfer pricing changes, but should also interpret all . . .
CIAT-SECO partnership strengthens Latin American and Caribbean tax administrations
Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium, discuss recent activities of the Inter-American Center of Tax Administrations (CIAT) and the State Secretariat for Economic Affairs of the Swiss Government (SECO) to assist tax administrations in Bolivia, El Salvador, Guatemala, Guyana, Honduras, and Nicaragua with transfer pricing and other issues . . .
OECD publishes peer review reports on tax dispute resolution in US, Belgium, Canada, Netherlands, Switzerland, UK
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
OECD releases revised discussion drafts on attribution of profits to PEs, profit splits
The OECD today released revised draft guidance on the attribution of profits to permanent establishments (PEs) as well as revised draft transfer pricing guidance on profits splits. Both discussion drafts replace earlier drafts . . .
Ireland releases Q&As on country-by-country reporting for multinationals
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
Andorra becomes 40th non-OECD/G20 country to join “inclusive framework” for BEPS implementation
Andorra has become the 40th country that is neither an OECD nor G20 member to join what is known as the inclusive framework for BEPS implementation, a group of countries that have pledged to adopt measures, designed by the OECD and G20 in the base. . .
OECD draft addresses multinational banks and insurance companies that take excessive interest deductions
The OECD today issued draft rules to be used by countries that seek to prevent multinational banks and insurance companies from avoiding tax through excessive interest . . .
OECD sets criteria for labeling countries as “non-cooperative” tax jurisdictions, previews coming tax guidance
The OECD has devised proposed criteria for determining if a country is a “non-cooperative” tax jurisdiction, an official said during a July 12 OECD webinar. OECD officials also discussed plans to release further tax and transfer pricing . . .
New OECD country-by-country reporting guidance provides for voluntary filing
The OECD today issued further guidance implementing the new transfer pricing documentation and country-by-country (CbC) standards of action 13 the OECD/G20 base erosion profit shifting plan. The guidance is designed to ensure consistent implementation . . .