Taiwan’s tax authority has announced that if a foreigner stays in Taiwan for more than 90 days during a taxable year, remuneration received outside Taiwan for services rendered within Taiwan is deemed . . .
Taiwan’s National Taxation Bureau of Central Area (NTBCA), in a Sept. 10 press release, said that it denied a company a deduction for a capital loss arising from the company’s ownership of a non-operating overseas holding company which held a lower tier investee company that had operating losses. . . .
Nigeria’s Federal Inland Revenue Service (FRIS) has notified nonresident companies that they must include audited financial statements and tax computations of actual profits . . .
UK businesses that supply digital services, including broadcasting, telecoms and e-services
. . .
The Obama administration on November 19 issued another package of tax measures designed to make it more difficult and less profitable for US companies to invert. The guidance, Notice 2015-79 supplements measures . . .
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 . . .
The EU VAT Expert Group has released an opinion welcoming the extension of an EU pilot program on cross border VAT rulings and suggesting that the rulings be made public. Under the . . .
The Seychelles Revenue Commission has released draft transfer pricing guidance, Public Ruling 2015-3, on the application of arms length principle. The guidance, which . . .
US IRS on February 10 published final regulations on foreign tax credit splitting events, clarifying aspects of the proposed and temporary regulations’ definitions of splitter arrangements and clarifying mechanical rules for tracking split taxes and related income. The government said it will address more mechanical issues associated with tracking related . . .
The Cayman Islands will not adopt a public central register of beneficial owners of companies and other entities, the government confirmed December 30, in a report following a consultation on the matter. The government did commit to improving its current system of providing beneficial ownership information to law enforcement, tax, and regulatory
. . .
The UK HMRC on October 18 published supplementary guidance on anti-avoidance rules that exclude some creditor loan relationships from being considered “qualifying loan relationships” for purposes of the controlled foreign companies (CFC) finance company exemption. The guidance notes that the OECD/G20 base erosion profit shifting project and potential changes in US tax laws, such as laws targeting the use of hybrid entities . . .
The US IRS on October 9 released guidance on what constitutes a “transaction” for purposes of section 7701(o), which disallows tax benefits when a transaction lacks economic substance. The guidance also clarifies when the IRS will apply related penalties provisions of Section 6662(b)(6).
The IRS states that a “transaction” under . . .
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 . . .
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 Australian Taxation Office (ATO) intends to enter into discussions with about 80 multinational enterprises expected to be affected by an antiavoidance law introduced into Parliament . . .
Japan’s National Tax Agency has released English-language information, forms, and instructions to be used by foreign businesses subject to a new law that imposes consumption tax on the overseas supply of digital . . .
The Australian Taxation Office on March 19 ruled that a nonresident entity that invests indirectly in an Australian resident company through one or more interposed entities where the final leg in the chain is a debt interest . . .
South Korea’s parliament has passed a tax reform package which includes a new 10 percent tax on the excess cash reserves of large corporations, a new tax on capital gains from derivatives transactions, more stringent thin cap rules, and reporting requirements for cross-border related party . . .
The French Tax Administration, on April 15, released draft regulations on anti-hybrid financing provisions, according to a release by EY.
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. . .
A proposal to establish a committee of inquiry in European Parliament to investigate the private tax ruling practices of member states gained the required support of 25 percent of lawmakers on January 14, moving the measure one step closer to being voted on by the full parliament. The question of whether to set up the committee . . .
The Inland Revenue Authority of Singapore (IRAS) on January 6 released updated transfer pricing guidance in an e-Tax Guide, consolidating four previous e-Tax Guides into the document. The 102 page document discusses the application . . .
Luxembourg has brought two actions in EU General Court asking the court to annul European Commission decisions that direct Luxembourg to provide information on its intellectual property taxation scheme and to provide the Commission with a list of advance tax rulings issued in 2010, 2011, and 2012 involving cross-border transactions . . .
Australia, on July 11, announced a consultation on proposed legislation designed to ensure that foreign pension funds
. . .
Mauritius Prime Minister, Dr Navin Ramgoolam and newly appointed Indian Prime Minister, Shri Narendra Modi, on May 28, announced . . .
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
European Commission President Jean-Claude Juncker told parliamentary committees January 17 that the EU should adopt rules governing private rulings . . .
The South Africa National Treasury announced in a June 5 media statement that the government intends to introduce draft legislation providing that issuance of shares by a South African resident company as consideration . . .
The UK’s HM Revenue Customs on April 13 notified UK financial institutions that UK FATCA guidance will be amended to remove the requirement to file nil returns and to no longer require FATCA reporting by most holding and treasury companies. HMRC said the US IRS has changed its . . .
The Australian Taxation Office (ATO) on February 26 released guidance on procedures that must be followed before ATO personnel can advance the view that a transaction must be reconstructed for transfer pricing purposes using one of the exceptions. . .
Tax arrangements that PwC promoted in Luxembourg, revealed through the “Lux Leaks” scandal, bear all the hallmarks of a mass-marketed tax avoidance scheme, according to a UK Public Accounts Committee report . . .
China signed 19 advance pricing arrangements (APAs) — 11 unilateral APAs and 8 bilateral APAs — in 2013, according to the State Administration of Taxation’s (SAT) annual APA report. The report, released December 5, provides data on China’s APA program from 2005-2013, outlines the process for obtaining an APA in China, provides forms and schedules needed to apply for an APA, and provides
. . .
The Belgian Tax Authority, in Circular AAFisc NR 13/2014, released April 3, clarifies aspects of the Fairness Tax, but leaves unresolved issues such as how to calculate the tax on permanent establishments of non-resident companies and the issue of the potential incompatibility of the new law with the Belgian Constitution, EU law, and double tax treaties, EY writes in a report on the new tax.
The EU Commission announced October 12 that it has made changes to its consolidated list of non-EU countries deemed non-cooperative for tax purposes, as identified by the Member States. The updates to the list, located on the Commission’s . . .
UPDATE (10/14/2015): Hong Kong Treasury notes the removal of Hong Kong from Spain and Estonia’s blacklists: The government said that allegations that Hong Kong are a tax haven are unfounded. See, release.
Irish Revenue on August 28 released five tax manuals on recent corporate tax law changes, including guidance on new tax residency rules that make it more difficult for multinationals to take advantage of the “Double Irish” tax loophole and rules that change capital allowances for . . .
The OECD on June 1 released submissions from 45 organizations commenting on proposed revisions to the OECD transfer pricing guidelines dealing with cost contribution. . .
Singapore’s Finance Minister and Deputy Prime Minister, Tharman Shanmugaratnam, released of the country’s Budget 2015 on February 23. Business will benefit from the budget’s extension of the 30% corporate income . . .
The European Commission on December 19 invited interested parties to comment on its investigation into whether an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary constitutes illegal state aid. The Commission said it currently. . .
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