Switzerland on November 19 signed a multilateral competent authority agreement, moving the country one step closer to adopting automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2018 . . .
Finance Minister Joe Oliver on October 10 tabled in the House of Commons tax proposals to implement the government’s budget and about a dozen tax proposals not included in the budget.
International tax . . .
The EU needs to be mindful of tax competition from countries outside the EU and adopt policies that will allow EU companies to remain competitive, Airbus’s head of tax, Guillaume de La Villeguérin, told the European Parliament’s Special Committee . . .
The US Court of Appeals for the Fifth Circuit has ruled, in BMC Software Inc., decided March 13, that accounts receivables created under a transfer pricing closing agreement are not a related-party loans causing partial disallowance of the . . .
The US IRS on March 6 published proposed regulations (REG-100400-14) modifying rules that determine how to report a company’s items of income and deduction that occur on the day the company joins or leaves a consolidated group. The proposal would alter regulations . . .
The South African Revenue Service on February 12 released draft guidance interpreting special tax incentives for headquarters companies, designed to encourage MNEs to locate operations in South Africa as a gateway to African investment. The law, effective for tax years after January 1, 2011, provides special tax breaks for qualifying. . .
Colombia’s president has signed into law a tax reform package which includes a temporary annual tax on wealth in excess of $1 billion pesos (USD 425,000) held by domestic or foreign legal entities, writes PwC in a December 28 tax alert. The tax package also includes increases in income tax withholding rates . . .
India’s Supreme Court has ruled that the law establishing India’s National Tax Tribunal (NTT) is unconstitutional, including a section of the law that allowed chartered accountants and corporate secretaries to represent parties before the NTT.
The decision concerns the 2005 NTT Act, which established specialized tribunals . . .
The Australian Taxation Office has ruled, in a May 30 interpretative decision. . .
The OECD on July 9 launched consultation on a draft paper offering guidance to low income countries on the use of tax incentives for investment. The consultation responds to a G20 Development Working Group’s. . .
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
Switzerland’s Federal Council announced June 24 that it will no longer pursue reforming the withholding tax system applicable to bond interest switching from the debtor principle to the paying agent . . .
The US IRS has released its annual “no rule” list, adding FATCA issues to the list of issues that the agency will “not ordinarily” address in private letter rulings or determination letters. . .
China and Russia on October 13 signed an agreement for the avoidance of double taxation. The agreement would replace a tax treaty signed by the countries in May 1994. Under the new agreement, dividends . . .
The UN’s Financing for Development Office has released papers authored by prominent international tax professors in preparation for a workshop, “Tax Base Protection for Developing Countries,” to be held on Sept. 23.
The workshop is the second of a . . .
The U.S. IRS, on July 29, released an advance copy of Notice 2014-45, which expands on Notice 2014-44, released its July 21, concerning dispositions of assets following a section 901(m) covered asset . . .
The Australian Taxation Office (ATO) on December 10 said it is reviewing arrangements where an Australian resident multinational establishes a controlled foreign . . .
The US IRS has issued final guidance under section 871(m) on dividend equivalent payments made to foreign corporations and nonresident aliens. The regulations, published in the Federal Register on September 18, establish . . .
The UAE Ministry of Finance’s (MoF) said August 18 that while Gulf Cooperation Council (GCC) countries have agreed to simultaneously launch a value added tax (VAT), the countries have yet to settle. . .
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 . . .
Data suggests that while the existence of a patent box regime incentivizes multinationals to shift the location of their patents, the shift is usually not accompanied by an increase in research activities or . . .
The US IRS signed significantly fewer advance pricing agreements (APAs) in 2014 as compared to the two previous years, according to statistics released by the goverment on March 30. A total of 101 APAs were signed in 2014, as compared to 145 in 2013 and 140 in. . .
EU finance ministers on December 9 adopted a directive to extend mandatory automatic exchange of information between tax administrations to interest, dividends, and other income, and to account balances and sales proceeds from financial . . .
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 . . .
China’s central government on Sept. 25 announced it will offer tax breaks to encourage enterprises to upgrade equipment and increase research and development (R&D) in an effort to improve the manufacturing . . .
The EU Commission on October 8 launched a public consultation on an EU-wide common consolidated corporate tax base (CCCTB). Through the . . .
Canada resolved 115 Mutual Agreement Procedure (MAP) program cases through negotiations with other countries during FY 2014/2015, slightly more than the annual tally of settled negotiable MAP cases in preceding periods . . .
The Indian government has announced that it has settled 35 transfer pricing disputes with the US in the information technology services and information technology enabled services industries thanks to a framework agreement signed . . .
India’s Lok Sabha on March 30 passed through a voice vote Finance Bill 2015, which contains the government’s tax proposals. The bill was passed after Finance Minister Arun Jaitley offered several amendments, including one that provides that foreign firms will be exempt . . .
The State of California Franchise Tax Board (FTB) has concluded that some payments received pursuant to a cost sharing arrangement (CSA) constitute gross receipts for purposes of the California sales factor. In TAM 2015-1, dated . . .
The European Commission has announced that it is assessing different options for a new EU VAT regime for business-to-business (B2B) supplies of goods based on taxation at destination. The work is a step toward the goal of a complete overhaul . . .
An unpublished draft report written by PwC in its role as contractor for the European Commission concludes it would be good for the economy if the EU requires banks to publicly release data such as turnover, profit and loss, and taxes, on a country-by-country basis, according to an Oct. 2 article by EurActiv. The PwC report will
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 UK on October 5 released draft regulations to implement country-by-country tax reporting to tax authorities . . .
Germany and The Netherlands have agreed to immediately begin spontaneous exchange of tax information on some advance pricing agreements (APAs) and on Dutch innovation and patent box rulings, Germany’s . . .
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 . . .
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 . . .
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