The UK’s HM Revenue and Customs on February 9 denied that Google received a “sweetheart deal” in a settlement that allowed the company to pay £130 million (USD 185 million) to resolve ten years of back taxes. The settlement, announced by Google on . . .
As part of an effort to devise an EU-wide common list of tax havens, the EU Commission today released a scoreboard designed to help identify countries located outside the EU that enable multinational corporation tax avoidance. Eighty-one countries – including the US, China, and India – were identified. . .
Swiss tax officials intend to sign next week a multilateral agreement to implement country-by-country reporting developed under the OECD/G20 base erosion profit shifting (BEPS) plan, Switzerland’s Federal . . .
The Australian Treasury on February 11 opened a consultation on whether Australia should adopt into law final OECD/G20 base erosion profit shifting (BEPS) transfer pricing . . .
The US Senate early Saturday morning passed its version of tax reform on a 51-49 vote. Like the House bill, passed in November, the Senate bill’s international tax provisions would dramatically alter the taxation of US and foreign-parented multinationals. In a late change, the Senate increased the tax rate on deemed repatriations of currently deferred . . . .
The international tax proposals in President Obama’s fiscal year 2017 budget, released February 9, look a lot like the proposals in last year’s budget. The administration has again proposed a one-time 14 percent tax on . . .
The UK on February 26 issued final rules requiring large UK-parented multinationals and some UK subsidiaries of large multinationals to file annual country-by-country reports to HM Revenue and Customs (HMRC). The regulations finalize draft regulations on the topic . . .
A tax treaty between Japan and Chile signed January 21, 2016, has entered into force, the Japanese government . . .
The European Commission today published a non-confidential version of its decision to open a State aid investigation into whether a tax rulings granted by Luxembourg to Engie, formally known as GDF Suez . . .
The Australian Taxation Office (ATO), on February 15, issued draft guidance elaborating upon proposed goods and services tax (GST) legislation introduced by the government last week. The guidance concerns aspects of new rules which would narrow the current test for determining when the enterprise of a nonresident . . .
India and the UK have signed two bilateral advance pricing agreements (APAs) to resolve transfer pricing disputes, the first such agreements between the nations, India’s . . .
Singapore’s Inland Revenue Authority (IRAS) on January 4 published the third edition of its transfer pricing guidelines, adding new information on the cost plus method and changing the guidance to reflect Singapore’s . . .
The Netherlands Ministry of Finance has issued guidance on new transfer pricing documentation standards . . .
The US IRS has released its annual “no rule” list, adding foreign base company income issues to the list of topics that the agency will “not ordinarily” address in private letter rulings . . .
The UK’s HM Revenue and Customs, on December 22, issued a series of draft examples illustrating the application of hybrid mismatch rules in previously released tax . . .
The BRIC countries of Brazil, Russia, India, and China have agreed to strengthen cooperation in areas such as transfer pricing and automatic exchange of financial account information to jointly crack . . .
The US IRS on December 21 released proposed regulations requiring annual country-by-country reporting . . .
The Australian government on December 17 issued detailed guidance on newly enacted Subdivision 815-E of the Income Tax Assessment Act 1997 concerning transfer pricing documentation . . .
The US IRS, on August 7, has requested public comments on the information collection requirements related to compensatory stock options under section 482 transfer pricing regulations . . .
The European Commission has launched a call for applications for a newly established expert group on automatic exchange of financial account information for direct taxation purposes. The . . .
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
Japan and Germany have reached an agreement in principle on a new tax treaty, Japan’s Ministry of Finance announced July 16. The new treaty will include an arbitration clause . . .
The US Treasury Department has updated its FATCA website, reporting that the Philippines has signed a Model 1 intergovernmental agreement (IGA) with the United States as of July 13. . .
The OECD on January 19 released comments to a discussion draft under action 14 of the base erosion profit shifting (BEPS) plan dealing with making cross-border tax dispute resolution mechanisms more . . .
Switzerland’s Federal Council on January 14 launched two consultations on legislation that would enable automatic exchange of tax information with other nations. One consultation concerns approval and implementation of the OECD/Council of Europe Convention . . .
The National Taxation Bureau of Taipei, Ministry of Finance (NTBT) on December 31 issued English-language guidance on a new law which reduces by half the tax credits available when dividends are paid to foreign or domestic taxpayers. The new law, passed by the
. . .
The US IRS on December 1 released an advance copy of guidance that provides that countries that have reached FATCA intergovernmental agreements (IGAs) “in substance” that do not sign an IGA by December 31 will continue to be treated as if an IGA was in effect as long as the country displays a “firm resolve” to sign an IGA as soon as possible. The new guidance . . .
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