Multinational
OECD updates tax guidance on common reporting standard, CRS XML schema
The OECD has issued new tax guidance on the common reporting standard, including the CRS XML schema, writes Davide Anghileri of the University of Lausanne . . .
No harm to EU investment under corporate debt-bias tax reform, Commission paper concludes
Davide Anghileri of the University of Lausanne discusses an October 27 EU Commission working paper on debt bias tax systems of the EU member states which concludes that reform can be revenue neutral and maintain EU investment . . .
OECD releases 17 comments on draft addressing MNE tax avoidance though branch mismatches
The OECD has released 17 comment letters responding to a draft report that explores how countries can improve their tax laws to counteract tax avoidance by multinational enterprises (MNEs) through . . .
Promoting tax certainty on the agenda of the next G20 presidency
The issue of tax certainty will be addressed by the G20 when Germany takes up its presidency in 2017, said Martin Kreienbaum, Director General, International Taxation, at Germany’s Federal Ministry of Finance at the 2016 OECD International Tax Conference . . .
Romania joins countries leading BEPS plan implementation to fight MNE tax avoidance
The Romanian government, on June 2, announced that it will join countries working on the next phase of the OECD/G20 base erosion and profit shifting (BEPS) project as an associate, developing standards and monitoring the implementation of the BEPS . . .
EU state aid decisions on Starbucks and Fiat tax rulings challenged in court
As expected, the EU Commission will need to defend in court its contention that advance pricing agreements (APAs) granted to a Starbucks subsidiary by the Netherlands and to a Fiat subsidiary by Luxembourg . . .
Australia proposes anti-hybrid law to combat multinational tax avoidance, announces plans for “targeted integrity rule”
The Australian government on November 24 released a draft law and explanatory materials implementing hybrid mismatch rules to combat multinational firm tax avoidance. The Australian government is also developing a “targeted integrity rule” to prevent circumvention of the hybrid mismatch rules as well as branch mismatch rules to further clamp down on MNE tax . . .
OECD releases 33 comments to draft guidance on tax treaty access by non-CIV funds
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Profs argue that BEPS concerns better addressed if passive income taxed at source, active income taxed at residence, Reuven S. Avi-Yonah & Haiyan Xu / SSRN→
See: Why BEPS and MAATM are Inadequate Responses, and What Can Be Done About It, by Reuven S Avi-Yonah and Haiyan Xu. Available at: SSRN.
Report details UN Committee of Experts’ fourteenth session on international tax
An official report describing the outcome of the fourteenth session of the UN’s Committee of Experts on International Cooperation in Tax Matters (Committee of Experts) was released on the UN website this week. The fourteenth session . . .
Apple to argue in State aid case that Irish subs’ profits belong to US
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission’s State aid decision against Ireland, published today in summary form, noting that Apple’s arguments diverge somewhat from Ireland’s arguments. . .
BRICS: tax policies should enhance growth, address BEPS
BRICS leaders, following their summit held October 15–16, called for tax policies that promote inclusive growth and expressed support for the implementation of the OECD/G20 base erosion profit shifting . . .
Kuwait signs tax transparency agreement
The OECD has announced that Kuwait has signed the CRS Multilateral Competent Authority Agreement, a step required to put into place automatic exchange of financial account information with . . .
Tax officials selected to chair OECD global forum and peer review group
Maria José Garde has been appointed as the new chair of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes and Huey Min Chia-Tern has taken over as chair of the . . .
China, India, Canada, Iceland, Israel, New Zealand agree to exchange of country-by-country transfer pricing reports
Officials from six countries today signed a multilateral agreement that sets out the parameters for the automatic exchange of country-by-country reports on large multinational corporations. China, India, Canada, Iceland, Israel, and New Zealand joined 33 other countries that have . . .
OECD releases electronic format for exchange of BEPS country-by-country tax reports
The OECD on Tuesday released a standardized electronic format for the exchange between tax administrations of country-by-country (CbC) reports about multinational . . .
EU ‘minimum effective taxation’ of interest, royalties among Dutch Presidency’s BEPS priorities
The Dutch Presidency of the EU hopes to achieve political agreement in the coming months on adding a clause on minimum effective taxation (MET) to the interest and royalties directive, according to a roadmap of the . . .
EU Commission VAT action plan coming in March, says Dijsselbloem
The EU Commission will offer in early March an action plan proposing VAT simplification and anti-VAT fraud measures, including an option for a reverse charge mechanism, officials. . .