OECD and the United Nations Development Programme (UNDP) officials on July 13 formally announced the launch of the Tax Inspectors Without Borders program at the UN’s Third International Conference on Financing for Development held in Addis Ababa, Ethiopia. The new program recruits currently serving or recently retired . . .
The World Customs Organization (WCO) has a published a guide for customs officials designed to move the debate forward on the issue of the harmonization of customs valuation and transfer pricing valuation.The guide . . .
India’s Lower House of Parliament on May 6 passed a constitutional amendment bill to introduce a GST to replace several local and central taxes and thus simplify India’s indirect tax regime. Moreover, during Lok Sabha debate, Finance . . .
Tax officials from 21 Asia Pacific countries and organizations attended an OECD regional network meeting on base erosion and profit shifting (BEPS) designed to give more nations a voice in the development of OECD/G20 base erosion profiting shifting (BEPS) plan output. The meeting, held February 12–13 in Seoul, also . . .
New Zealand is considering changes to its tax laws that would tighten nonresident withholding tax rules for interest, improve the quality and usefulness of tax information provided by large corporations, address the taxation of foreign trusts, and implement OECD base erosion and profit shifting (BEPS) output, according . . .
The Swiss Federal Council on Sept. 19 initiated a consultation on rules that would extend the flat-rate credit to permanent establishments in Switzerland that are domiciled in a country that has a direct tax agreement (DTA) with Switzerland. . .
The US Department of the Treasury’s Financial Crimes and Enforcement Network (FinCEN), on July 30, released proposed rules that would require banks and other financial institutions to learn and verify the identity of the beneficial owners of their legal entity clients . . .
Even though international agreements have been reached on combating tax avoidance through the OECD/G20 base erosion profit shifting (BEPS) plan initiative, it does not necessarily follow that US multinational . . .
US presidential candidate Donald Trump’s tax plan, unveiled September 28, includes proposals for a 15 percent tax rate on all business income, limits on interest deductions and other unspecified business deductions, a deemed repatriation of all overseas profits of US multinationals at a 10 percent rate, and an end to deferral. See: Trump plan. More: TaxVox, Fortune, Slate, Bloomberg, The Guardian, CNN, New York Times, Politico, Wall Street Journal.
The UK’s conservative party on July 8 unveiled its first budget of new the new term, proposing to reduce the 20 percent UK corporate income tax rate to 19 percent beginning April 2017 and to 18 percent . . .
The Netherlands on June 22 announced it has renegotiated tax treaties with Ethiopia, Ghana, Kenya, and Zambia to add antiabuse provisions to the treaties, and said that it hopes to add antiabuse clauses to tax treaties with 23 developing nations. Moreover, talks . . .
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
Guernsey’s Director on Income Tax on April 8 issued guidance on when companies incorporated overseas are deemed to be a resident of Guernsey because they are controlled there. Guidance was also released on the filing obligations of such companies. The guidance provides that, generally, companies incorporated overseas but . . .
The US IRS on January 12 announced that its international data exchange service (IDES) website is open for enrollment. Financial institutions and host country tax authorities use IDES to electronically send information reports on financial accounts held by US persons to the IRS under the FATCA or pursuant. . .
Luxembourg will provide the European Commission with a list of taxpayers that received private tax rulings in 2010–2012 involving cross-border dealings, as well as a list of the beneficiaries of its intellectual property regime, Prime Minister Xavier Bettel said December 18 . . .
OECD, G-20, and other tax administrator are working together on a project to map of the global operation of selected MNEs engaged in the digital economy, Australian Second Commissioner Neil Olesen said November 28. “In today’s world, multinationals . . .
McKesson Corp., which is appealing an adverse decision in a transfer pricing dispute in Canada’s Federal Court of Appeal, filed a motion to amend its appeal on November 3 claiming that actions taken by the trial judge in filing a lengthy “Reasons for Recusal,” gave McKesson additional grounds for appeal, writes Timothy Fitzsimmons of Dentons in a . . .
The European Court of Justice on April 30 dismissed the UK’s challenge to a EU Council decision that authorized 11 nation negotiations on a financial transaction tax. “The arguments relied on by the United Kingdom are directed at the elements of a future tax and not at the authorisation to establish enhanced cooperation,” the court said in a statement following the judgement. See, United Kingdom v Council, Press Release (164 KB).
The Dominican Republic will soon modify its transfer pricing regulations through publication of Executive Decree 78-14, reports EY. Read More: EY.
The EU Parliament on November 25 overwhelmingly approved wide-ranging proposals to overhaul Europe’s international tax system offered by a special Parliament committee investigating multinational . . .
UPDATE (11/26/2015): EU Parliament to establish new committee on tax rulings: The EU Conference of Presidents on November 26 decided to set up a six-month committee to follow up on the tax rulings committee’s work; the precise mandate of the new committee will be decided on Wednesday. See: Release.
UPDATE (12/02/2015): New EU Parliament tax committee will have same mandate as its predecessor: The European Parliament on December 2 voted to create a new committee to investigate tax rulings, specifying that the new committee will have the . . .
The UK government on October 22 launched public consultations on proposed rules designed to limit excessive corporate interest deductions and revise the country’s patent box regime. Both proposals respond to the OECD/G20 base erosion . . .
The OECD on June 15 released public comments from 60 organizations on a revised discussion draft under action 7 of the OECD/G20 base erosion and profit shifting (BEPS) plan concerning artificial avoidance of permanent establishment (PE) status. The comments, numbering 319 pages, generally express . . .
The European Commission has been forced to delay decisions on whether countries violated state aid rules by granting private tax rulings to Amazon, Apple, Fiat, and Starbucks, EU competition commissioner, Margrethe Vestager, said May 5 . . .
Tax measures in the Hong Kong government’s 2015-16 budget, released February 25, include tax reductions for corporate treasury centers and an extension of the profits tax exemption for offshore funds to private equity funds.. . .
A joint proposal advanced by the UK and Germany that put limits on preferential intellectual property regimes has been adopted by the OECD Forum on Harmful Tax Practices (FHTP) as a new starting point for drafting guidance under Action 5 the base erosion profit shifting (BEPS) plan, UK Financial Secretary to the Treasury, David Gauke said December 2. Gauke said the UK/German proposal . . .
German, French, and Italian finance ministers have asked the EU Commission to take immediate steps to more aggressively tackle corporate tax avoidance in the EU. In a letter addressed to European economy, finance and tax commissioner Pierre Moscovici . . .
The UK’s HM Revenue & Customs, on July 31, released draft implementing agreements and regulations for a common reporting standard for automatic exchange of information, and has requested stakeholder input . . .
Singapore and the US have initialed a Model 1 Intergovernmental Agreement (IGA) to facilitate compliance with the U.S. Foreign Account Tax Compliance Act (FATCA). IRAS Press Release
Poland’s Counsel of Ministers, on March 18, adopted guidelines to draft legislation that would modify Poland’s advance pricing agreement program, according to KPMG’s Poland office. Read more: KPMG
Japan closed 174 mutual agreement procedure (MAP) cases during the fiscal year ending June 30, 2014, a record high, Japan’s National Tax Agency (NTA) said in an . . .
The Australian goverment on July 7 launched a consultation on proposed legislation that would impose a 10 percent withholding tax on the disposal of Australian property by foreign residents. The tax is designed to . . .
The European Commission on June 8 escalated its inquiry into whether EU countries’ tax ruling practices provide a selective advantage to companies in violation of state aid rules, asking 15 EU nations to provide the . . .
The OECD on May 5 released public comments to an OECD discussion draft that provides recommendations on how countries can design effective controlled foreign companies (CFC) rules to combat base erosion and profit shifting (BEPS). Sixty-two comments were released in response to the guidance, issued April 3 in response to action 3 of the OECD/G20 BEPS. . .
The EU Joint Transfer Pricing Forum (JTPF) has proposed modifications to the EU Arbitration Convention and revised Code of Conduct to better accommodate transfer pricing disputes. in a report released on its website, the JTPF . . .
The G20/OECD base erosion profit shifting (BEPS) project is in its “decisive stages,” with only six months remaining until the 15 BEPS deliverables must be completed, Angel Gurría Secretary-General of the OECD said at a meeting of World Bank Group and International Monetary Fund officials, G20 Finance Ministers, and Central Bank Governors held . . .
New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on March 24 concerning reporting deadlines and nil reporting. . .
The OECD on January 12 released public comments to discussion drafts under the OECD’s base erosion and profit shifting (BEPS) action plan which deal with the prevention of tax treaty abuse and with the artificial avoidance of permanent establishment (PE) status. Eighty comments were released on the tax treaty . . .
The Australian Taxation Office (ATO) on December 17 released a final ruling and two practice statements dealing with transfer pricing documentation and penalties. Final ruling TR 2014/8 outlines . . .
The EU Commission’s new president, Jean-Claude Juncker, on November 27, survived a no-confidence vote in European parliament brought on account of the ‘Lux leak” revelations that Luxembourg helped scores of multinationals avoid tax while he was prime minister. The censure motion . . .
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