Transfer Pricing
OECD report reveals disagreement on taxation of digital firms
A highly anticipated OECD interim report, published today, reveals that there is still no consensus among countries on whether changes should be made to international tax rules that apply to multinational digital firms. Countries did agree to study international tax concepts to see if improvements can be made, though. Also, while the report states that there is no consensus on short-term interim measures to tax the digital economy either, countries . . .
Experts consider next round of US international tax changes, BEAT as leverage in EU tax negotiations
With the ink still drying on a sweeping reform of the US international tax system, academics, economists, government officials, and tax practitioners gathered in Washington at the February 2 IIEL & ITPF tax conference to offer suggestions on how to replace or revise the new law and discussed how to the BEAT might be used as leverage in tax negotiations with the EU . . .
Idan Netser joins Fenwick & West as tax partner
Mountain View, California, firm, Fenwick & West, announced November 20 that Idan Netser has rejoined the firm as a tax partner. Netser’s practice focuses on all areas of corporate taxation, including international, corporate, and partnership taxation, transfer pricing, foreign tax credits, tax planning and restructuring, international joint ventures . . .
UN committee weighing major updates to model tax treaty, other guidance
The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . .
IRS announces issue-based campaign to increase tax compliance of large companies, international business
The US IRS has announced that it has selected 13 tax and transfer pricing topics that it will focus on in an issue-based campaign to increase the tax compliance of large and/or international businesses. In a January 31 announcement, the IRS’ Large Business and International division (LB&I) said it will . . .
Switzerland launches consultation on exchange of multinational corporation country-by-country tax reports
Switzerland’s Federal Council on March 13 initiated a consultation on legislation that would give effect to a multilateral agreement signed . . .
Indian tax agency announces signing of seven more APAs
India has signed seven more unilateral advance pricing agreements (APAs) with multinationals, India’s Central Board of Direct Taxes (CBDT) announced January 22. The . . .
India to accept transfer pricing APA, MAP applications even if corresponding adjustment treaty provision absent
The Indian government today clarified that it will accept transfer pricing mutual agreement procedure (MAP) cases and bilateral advance pricing agreement applications in situations where the applicable tax treaty does not include a provision comparable to Article 9(2) of OECD Model Tax Commentary, providing for corresponding adjustments. A Central . . .
UAE signs multilateral treaty to fight offshore tax evasion and multinational corporation avoidance
The United Arab Emirates on April 21 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 109th jurisdiction to participate in the convention. The treaty, developed in 1988 by the OECD and the Council of Europe, would enable . . .