The UN’s Financing for Development Office has released the United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries, compiling in one publication ten papers authored by prominent international tax professors . . .
The US is disappointed with much of the OECD/G20 base erosion profit shifting (BEPS) plan output, particularly work on permanent establishments (PEs), though it supports efforts on country-by-county reporting, dispute resolution, hybrids, and interest stripping, US Treasury officials said June 10–11 in Washington at the 2015 OECD International . . .
KPMG International has named William O’Mara as its new global head of audit, effective March 1 . . .
In comment letters released February 11, business representatives argued that the OECD should not adopt a proposal to limit MNE interest deductions using a group-wide test, as proposed in a discussion draft released under OECD base erosion and profit shifting (BEPS) plan. Just over 100 comment letters were released in response to the discussion draft, issued December 18 . . .
European Court of Justice Advocate General Juliane Kokott in an October 23 opinion advised the ECJ to abandon the Marks & Spencer exception for loss relief for foreign group members and sanction UK legislation that restricts such loss relief.
Kokott said the . . .
The Rascon CPA Firm has provided a report of October 3 comments made by Robert Stack, Treasury deputy assistant secretary (International Tax Affairs) concerning the OECD’s base erosion . . .
The OECD has published entries in its online library for the 13 final reports to be delivered under the OECD/G20 base erosion profit shifting (BEPS) plan, adding summaries of 11 reports that reveal some of the content of the coming . . .
G20 finance ministers have agreed to a plan to create a multilateral instrument to implement tax treaty-related measures under OECD/G20 the base erosion and profit shifting (BEPS) plan, the ministers said in a communique following their February 9-10 meeting in Istanbul . . .
The European Commission, on July 11, launched a public consultation on the potential economic consequences of going forward with a requirement that financial intuitions publicly report, on a country-by-country basis, their profit and loss before tax, their tax on profit or loss, and public subsidies received. The country-by-country reporting requirement is slated to take effect January 1, 2015. . .
US Republican congressmen, in a June 2 statement, said they were concerned that some countries see the OECD base erosion and profit shifting (BEPS) project as a means to “raid the American Treasury.” . . .
The OECD has released two discussion drafts on BEPS action item 2, which calls for development of model treaty provisions and recommendations regarding the design of domestic rules to neutralize the effects (double non-taxation, double deduction, and long term deferral) of hybrid mismatch arrangements.
Comments are requested by May 2014, Press Release; Discussion Draft on Treaty Issues; Discussion Draft on Recommendations for Domestic Laws; Analysis: EY, Deloitte
China and Monaco have signed the multilateral competent authority agreement, moving the countries one step closer to adopting automatic exchange of financial account information for tax purposes . . .
The final version of the rewrite of Chapter 1 of the OECD Transfer Pricing Guidelines concerning delineation of transactions, risk, recharacterization, and special measures will be “quite different” from draft guidance on the topic released last December, Joe Andrus, consultant and former head of the transfer pricing unit at the OECD, said . . .
The OECD on May 13 released comments to a discussion draft under action 11 of the base erosion and profit shifting (BEPS) plan on improving the availability and analysis of data on BEPS and on monitoring the effectiveness and economic impact of actions . . .
Australia and the UK have asked G20 nations to join them in an effort to stop the diversion of profits by multinational enterprises, in an initiative designed to go “further and faster” than the OECD’s base erosion and profit shifting (BEPS) plan, Australia’s . . .
The OECD on April 3 released a discussion draft that provides recommendations on how countries can design effective controlled foreign companies (CFC) rules to combat base erosion and profit shifting (BEPS). Released in response to action 3 of . . .
European Court of Justice Advocate General, Niilo Jääskinen, issued his opinion February 26 that freedom of establishment principles do not prevent Germany from imposing tax on unrealized gains inherent in assets located in Germany upon the transfer . . .
The OECD on February 10 released public comments to three discussion drafts that propose to modify OECD transfer pricing guidelines in response to the OECD/G-20 base erosion profit shifting (BEPS) plan. Eight-three public comments were released . . .
A UN subcommittee is seeking stakeholder comment on a package of draft recommendations designed to assist developing countries formulate policy, craft tax laws, and negotiate tax treaties to meet objectives in taxing the extractive industry. In a November 18 notice . . .
The OECD on Sept. 16 published its first set of deliverables under the OECD/G20 Base Erosion and Profit Shifting (BEPS) action plan along with an official Explanatory Statement
. . .
Israel became the 91st signatory of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on November 24, the OECD . . .
The G20 leaders at their summit in Antalya on November 15-16 endorsed the 13 final reports developed under the G20/OECD base erosion and profit shifting (BEPS) project and . . .
Mauritius on June 23 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has announced. The country is the 87th signatory to the . . .
Walmart has stashed billions in 78 subsidiaries and branches located in 15 overseas tax havens, employing well-known international tax strategies to avoid paying foreign taxes in countries where it has retail operations and US taxes on foreign earnings, writes Americans for Tax Fairness in a . . .
Even if Ireland eliminates the Irish incorporated non-resident company, as proposed in 2015 Irish budget, the tax benefits of the “double Irish Dutch sandwich,”can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation because of provisions in Ireland’s existing tax treaties with those nations, writes Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.
A European Commission report released October 23 estimates that €177 billion in VAT revenues was lost due to non-compliance or non-collection in 2012. The VAT Gap study provides VAT collection trends among 26 EU Member States and analyzes the impact that the economic climate and policy decisions have on VAT revenues. See, report (985 kB), release.
The UK’s HM Treasury announced on October 6 that the UK government intends to propose rules to address hybrid mismatch arrangements consistent OCED/G20 base erosion profit shifting (BEPS) plan guidance on the topic.
The government will publish a consultation on . . .
UK registered logging, mining, gas, and oil companies will be required to report payments made to the governments of all the countries they operate in for financial years from January 1, 2015, the UK government has announced.
The new draft reporting requirements, released August 21, implement . . .
Officials from 86 countries endorsed new OECD guidelines on the application of VAT to international trade during the OECD’s April 18-19 Global Forum on VAT in Tokyo. Through the guidelines, the OECD seeks to ensure that VAT laws have a neutral effect on production and that domestic and foreign businesses are taxed equally in cross-border trade. The standards also seek to ensure that international business-to-business trade in services and intangibles is only taxed in the country of the customer. The OECD also said it is working to extend guidelines to cross-border sales of services to private consumers, to produce anti-abuse rules, and to craft provisions on mutual cooperation and dispute minimization. OECD VAT guidelines (1.5 MB), OECD Press Release, Statement of Outcomes, Speech of OECD Deputy Secretary-General Rintaro Tamaki., BIAC press release.
The OECD on March 11 released a paper on the availability of transfer pricing comparability data for developing countries. The paper was prepared in response to a request by the G8 at its Lough Erne summit, “to find ways to address the concerns expressed by developing countries on the quality and availability of the information on comparable transactions that is needed to administer transfer pricing effectively.” Press Release, Paper
The OECD will provide effective mechanisms to resolve cross-border double taxation disputes in guidance under the OECD/G20 base erosion profit shifting (BEPS) plan, including mandatory and binding arbitration for those countries willing to adopt it, an OECD official said June 8 during an update of the OECD’s progress . . .
Australia will introduce transfer pricing documentation requirements for multinationals, including country-by-country reporting, consistent with guidance developed under the OECD/G20 base erosion and profit shifting (BEPS) plan, the government announced in 2015 budget papers released May 12. The government also released exposure drafts of legislation for a new targeted antiavoidance rule that is aimed at . . .
The Netherlands State Secretary of Finance on December 1 expressed support for a UK/German agreement to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting plan, but said that incentives should not be limited to activities that are legally protected, such as by patent, writes EY in a December 5 tax alert. The Netherlands does not plan major revisions to its innovation box regime, EY reported. For discussion, See EY.
Gabon, on July 3, signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.. Gabon is the 66th nation to sign the convention. Release.
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual administrative assistance treaty. . .
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