PwC’s Kevin Nicholson has been called to testify before the UK House of Commons Public Accounts Committee (PAC) to discuss the role of large accountancy firms in multinational tax avoidance. The hearing will give PAC committee lawmakers the opportunity to grill Nicholson, who is head of tax at PwC UK, on the “Lux leak” documents . . .
The German Bundesrat on November 7 approved a draft tax bill that contains a number of important proposals, including anti-hybrid and anti-double dip rules that are more strict than OECD recommendations, writes Deloitte. A welcome proposal would broaden the intragroup restructuring exception. . .
A Scottish government proposal to introduce a general anti avoidance rule (GAAR) has gained the support of the Scottish Parliament’s Finance Committee. In a report released May 2, the Committee said . . .
For an analysis of a March 25 Denmark National Tax Board ruling concluding that a partnership structure did not create a permanent establishment in Denmark and that anti-avoidance rules did not apply, see Deloitte.
Members of the European Parliament Economic and Monetary Affairs Committee have expressed disappointment with a deal struck October 6 for a EU directive on automatic exchange of tax ruling i. . .
Australia has, for the first time, transmitted information to the US government on US-owned financial accounts under an arrangement designed to combat offshore tax . . .
The US Court of Appeals for the District of Columbia Circuit on August 14 rejected on procedural grounds a challenge to IRS regulations that impose a penalty if a bank fails to furnish information to the US government about interest earned by nonresident . . .
Representatives of nine multinational pharmaceutical companies will defend their companies’ tax practices before the Australian Senate’s Economics References Committee on July 1 as a part of the committee’s ongoing inquiry into tax avoidance and aggressive tax . . .
The Indian government, on June 11, released additional guidance on the availability of roll back for advance pricing agreements. The guidance, in a question and answer format, clarifies . . .
The Netherlands goverment supports expanding public release of country-by-country data beyond the extractive and banking industries to all companies, Eric Weibes, State Secretary of Finance . . .
The US IRS in Chief Counsel Advice 201516064 has ruled that none of a taxpayer’s controlled foreign corporation loans satisfy Notice 88-108 because one of its loans did not satisfy the . . .
The European Commission on March 26 made a formal request to Belgium to amend dividend taxation rules to comply with the parent-subsidiary directive. The Belgian law does not allow . . .
Spain has enacted major tax reform, including corporate tax reform, effective January 1, 2015, writes Deloitte in a December 2 alert. The corporate tax changes include a reduction in tax rates for 2015 and 2016, anti-hybrid rules and . . .
The US IRS in Chief Counsel Memorandum 201444039 released October 31 concluded that foreign tax redeterminations with respect to a controlled foreign corporation’s (CFC) pre-1987 accumulated profits, regardless of when made, are accounted for by adjusting . . .
The UK’s HMRC has released a revenue and customs brief concerning the impact in the UK of the European Court of Justice judgment in the Skandia America Corp. case . . .
The European Commission, on August 22, took another step toward addressing concerns that the Netherlands’ corporate tax exemption for Dutch public enterprises violates state aid, asking . . .
Six witnesses are scheduled to speak at a US Senate Committee on Finance hearing on international tax, set for July 22. The hearing is expected to address, among other issues, US legislators’ concerns about a recent spate of US multinational inversions undertaken to avoid U.S. tax.
Slated to testify are Robert B. Stack . . .
The European Union’s Joint Transfer Pricing Pricing Forum has published profiles of the transfer pricing policies of all EU member states, including competent authorities’ contact details and other information. JTPF Country Profiles
The EU Joint Transfer Pricing Forum has released statistics for 2014 on EU nation advance pricing agreements (APAs) and on pending . . .
The European Commission has announced that its current view is that Belgium’s excess profits tax ruling system provides for a selective advantage tantamount to State aid, and has requested stakeholder comments on this determination by July 5. According to the Commission, about 50 companies have used the program to reduce . . .
Switzerland’s Federal Council, on April 22, announced that it has instructed the Federal Department of Finance to create the legal basis for rules that would provide a flat-rate tax credit for foreign companies’ permanent establishments in Switzerland which have their registered office in a country with which Switzerland has a double taxation agreement. The credit would alleviate double . . .
The OECD’s Pascal Saint-Amans sought to allay Australian lawmakers’ fears that the OECD will fail in its mission to curb tax avoidance through its base erosion and profit (BEPS) plan during an Australian senate hearing, as the senators weighed whether they should support immediate unilateral tax measures to protect . . .
US lawmakers on January 29 revealed two different plans to address a shortfall in the US Highway Trust fund, each seeking revenue from US multinationals that defer tax on profits from overseas operations. US Senators Rand Paul, R-Ky., and Barbara Boxer, D-Calif., announced they will introduce legislation that would allow US companies to repatriate their foreign . . .
Irish Tax and Customs on January 13 released updated guidelines on calculating the research and development (R&D) tax credit that take into account new rules, effective tax years beginning January 1, which no longer require companies to subtract base year expenditures . . .
South Africa’s minister of finance on December 23 released for public comment a draft report that provides a detailed analysis of how South Africa should react to OECD/G-20 base erosion and profit shifting (BEPS) plan output . . .
Russia will begin automatic exchange of financial account information under the OECD/G20 Common Reporting Standard in 2018, Finance Minister Anton Siluanov told reporters November 17, Russian news agency TASS. . .
The UN Economic and Social Council on October 7 announced the appointment of three new members to the Committee of Experts on International . . .
The European Parliament’s special committee on tax rulings on Monday approved its final report, which will be released to the public sometime . . .
The US IRS on September 21 released final regulations regarding the qualification of a transaction as an F reorganization under section 368(a)(1)(F) by virtue of being a mere . . .
Seven US Democrats have written to Treasury Secretary Jack Lew, requesting that Treasury publish annually a list of inverted corporations . . .
OECD tax officials have expressed dissatisfaction with a blacklist of 30 tax havens prepared by the European Commission, as have several countries on the list . . .
Tax officials from 38 countries pledged to increase their cooperation and collaboration to better handle the increased workload associated with implementing OECD/G-20 base erosion profit shifting (BEPS) . . .
The European Commission announced on October 16 that it is referring Belgium to the European Court of Justice for discriminatory taxation of collective investment undertakings
. . .
The Obama administration has announced that it has taken regulatory action to make it more difficult and less lucrative for US companies to invert.
The new rules, which apply to deals closed on Sept. 22 or thereafter, are designed to stop post-inversion planning techniques that allow . . .
The IRS and Treasury on Sept. 23 published a notice which describes regulations that will be issued with respect to inversion transactions. See, Notice 2014-52.
China’s General Office of the State Administration of Taxation (SAT) highlighted recently issued tax guidance, “Interim Measures for the Tax Management of Non-resident Enterprises Engaged in International Transportation Business,” in a Sept 15 English-language news release. . .
Justice Patrick Boyle has recused himself from deciding all remaining issues in McKesson Canada Corporation’s transfer pricing proceedings in the Tax Court of Canada, including costs and confidentiality issues . . .
Two US senators have announced that they will move to tighten tax laws that discourage corporate inversions, while a third believes that comprehensive US tax reform is key to preventing . . .
Microsoft and the Indian tax authority are again fighting over transfer pricing profit margins, with Microsoft claiming that its Indian unit earned 16.4% profit in FY10, and the government claiming that a 61.5% profit is appropriate, according to report by Santosh Tiwari of The Financial Express.
In a September 25 letter, 24 international tax experts have urged the US Congress to reject legislative proposals calling for the adoption of a territorial tax system and for the immediate taxation US multinational . . .
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