The European Commission’s Joint Transfer Pricing Forum (JTPF) has released draft papers on improving the functioning of the EU arbitration convention and the EU code of conduct on transfer pricing documentation. The drafts, released in November, were . . .
Australia’s Senate on Oct 2 voted to conduct hearings on aggressive tax minimization by corporations registered in Australia and by multinational corporations operating . . .
The Australian Taxation Office (ATO), in TR 2014/3 released June 11, has ruled that a company
. . .
The Australian Government, on May 4, released draft legislation that would give the revised Australia-Swiss tax treaty and accompanying protocol, signed . . .
An anti-avoidance rule that would limit double tax relief, under consideration in U.K. Finance Bill 2014, sweeps in too many transactions and should be modified to require a tax avoidance purpose, according to KPMG’s UK office. The proposal limits double tax relief claimed with respect to loan relationships, derivatives, and intellectual property non-trading credits. KPMG
Revenue Minister Todd McClay on September 3 announced that the New Zealand goverment will introduce tax legislation early next year providing that there will be no income to a debtor upon the cancellation of a debt owed to a . . .
All EU states support the main objectives of the EU Commission proposal for mandatory automatic exchange of information on tax rulings, according to a report of the outcome of a June 19 ECOFIN meeting in Luxembourg. At the meeting, EU finance ministers also . . .
Multinationals asked to testify about their private tax ruling practices before the European Parliament’s Special Committee on tax Rulings on June 13 have mostly declined the invitation. According to . . .
The OECD/G20 base erosion profit shifting (BEPS) project work should not be used to adopt protectionist measures, Josephine Teo, Singapore Minister of State for Finance and Transport . . .
A consultation has revealed widespread support for a corporate tax reform plan, proposed last fall, to abolish the cantonal tax statuses for holding, domiciliary, and mixed companies, and to introduce a royalty box, Switzerland’s Federal Council said in an April 2 release. Some modifications to the reform proposals will be . . .
Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD’s effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .
US Senator Marco Rubio (R., Fla.), a likely 2016 Republican presidential candidate, and Senator Mike Lee (R., Utah) on March 4 released a tax plan that includes a proposal to adopt a territorial tax system. The Rubio-Lee plan would also . . .
The UK government on January 8 published a bill that would give Northern Ireland the power to set its own corporation tax rate beginning April 2017. If the bill is passed, it is expected that Northern Ireland will lower its . . .
Materials that accompany a UK draft law suggest that OECD/G20 base erosion profit shifting (BEPS) guidance will recommend that country-by-country reporting data be disseminated using a tax treaty mechanism, vastly limiting the scope of the reform, tax campaigners say . . .
“China will comprehensively monitor the profit levels of foreign companies to make sure there is no base erosion and profit shifting,” Zhang Zhiyong, deputy director of the State Administration of Taxation (SAT) said December 1, the government’s news agency, Xinhua, has reported. Zhang also said that China intends to . . .
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
The UK on Sept. 30 issued guidance explaining the conditions that must be met for holding companies to recover VAT. The guidance describes . . .
The government of Gibraltar, on July 24, opened a consultation on a proposal to establish a registry of the ultimate beneficial owners of Gibraltar companies. Input is requested on topics such as whether the registry should made available publicly or only to select users, and what type of information, beyond names and addresses, should be required. Submissions are due September 30. Consultation Paper (PDF 386KB)
The OECD BEPS project is not delivering promised international tax reform, and the result may be a breakdown of tax cooperation as countries abandon the project and take matters into their own hands, warns Richard Murphy, in an April 22 blog post.
Singapore and Sri Lanka signed a revised income tax treaty on April 3. Among other changes, the treaty lowers withholding tax rates for dividends and royalties and modifies provisions for determining permanent establishments. The treaty will enter into force after ratification by both countries. Treaty
US Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew asking Treasury stop work on a regulation project to . . .
Canada signed 31 advanced pricing arrangements (APAs) in FY 2014/2015, the most in five years, according to data released August 20 by the Canadian Revenue Agency (CRA). A total of 29 bilateral and 2 unilateral . . .
The OECD on April 4 released public comments on a discussion draft under action 12 the base erosion profit shifting (BEPS) plan dealing with mandatory disclosure rules. The draft guidance, issued March 31, provides recommendations to tax administrations on how to structure mandatory disclosure rules . . .
The OECD on February 24 released 47 comments to a discussion draft on OECD international VAT/GST guidelines relating to the place of taxation of business-to-consumer (B2C) supplies of services and intangibles. The draft, prepared under . . .
The Canadian Revenue Agency (CRA) has issued guidance on the use of multiple year data in determining the arm’s length price in transfer pricing cases. The guidance also address the use of statistical tools . . .
The OECD on Oct. 7 published comments to Action 11 of its base erosion profits shifting (BEPS) initiative concerning the establishment of methodologies to collect and analyze data on BEPS and the actions to address it.
The OECD received 28 comments, including submissions from China and Costa Rica, prominent academics, trade associations, and advisers.
The comments were submitted in response to an August 4 OECD request for input.
China and Germany signed a new income tax treaty and protocol on March 28, according to a report by EY.
The UK’s HMRC, in Customs Brief 23 issued December 11, updated its view of how UK businesses must account for VAT on intragroup supplies of services to branches that are part of VAT groups located in the Netherlands or Spain, following the European Court of Justice’s ruling in Skandia America . . .
The UK government on December 9 issued draft legislation for Finance Bill 2016, including measures addressing hybrid mismatch arrangements and the UK patent box, and introducing new transparency requirements for large corporations and partnerships. The government . . .
Responding to taxpayer requests, India’s Central Board of Taxation on March 31 announced an extension of the deadlines to apply for rollback of an advance pricing agreement (APA) for existing APAs and pending APA applications. June 30 is now the deadline to apply . . .
The General Court of the European Union on October 7 ruled that a Spanish tax incentive which allows for amortization of goodwill in foreign company share acquisitions is not incompatible with EU state aid rules. As such, the Court annulled 2009 and 20011 European Commission decisions . . .
Switzerland’s Federal Council and the EU member states on October 14 signed a joint statement on business taxation whereby the Federal Council reaffirmed its intention to propose abolishing tax regimes . . .
The UK government intends to end tax avoidance schemes used by technology companies, Chancellor of the Exchequer George Osborne said Sept. 29, reportedly referring to plans to target double Irish tax avoidance strategies.
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The Philippines Department of Finance is pressing for passage of the Tax Incentives Management and Transparency Act and the Fiscal Incentives Rationalization Reform Bill, stating that the bills would create a more transparent and accountable system for granting of tax incentives. The agency notes that tax incentives cost the government at least 1.5% of GDP in 2011 and that the International Monetary Fund supports the reform of the fiscal incentives structure.
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India has signed 11 more unilateral advance pricing agreements (APAs) with multinationals, bringing total APAs signed by the government so far this fiscal year to 22, the India’s Central Board . . .
Indian government on November 20 released more details of its plan, announced in Finance Minister Arun Jaitley’s budget speech, to reduce the corporate tax from 30 percent to 25 and to phase out deductions . . .
The European Commission on October 19 asked the Netherlands to amend the limitation on benefits clause in its tax treaty with . . .
The South African Revenue Service has released draft guidance to assist in determining whether an entity has an place of effective management in South Africa so as to be considered a resident of the Republic. The guidance concludes . . .
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