German tax professional Ninja-Antonia Reggelin discusses a German-Swiss agreement, made public March 3, which outlines the procedure for arbitration of tax disputes between the countries. . .
KPMG India on June 6 announced the appointment of Rahul Mitra to head the firm’s transfer pricing practice. Mitra, a partner, will also continue to lead the firm’s efforts regarding . . .
Jitendra Jain, Executive Director at PricewaterhouseCoopers, India, discusses India’s much-awaited rules on the implementation of the master file and country-by-country report, released yesterday, focusing on the differences between India’s master file requirement and the OECD’s prescribed format and recommending next-steps to comply with the requirements . . .
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
Paulus Merks, Jian-Cheng Ku, and Jesse Peeters of DLA Piper, Amsterdam, discuss today’s release by the EU Commission of three tax directives, the CCTB, CCCTB, and ATAD II, which will potentially have a significant impact on multinationals operating in the European Union . . .
Thirty-six countries and jurisdictions that are neither OECD nor G20 members have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, and 21 more are expected to join in the coming months, the . . .
Ireland’s tax authority on November 24 announced that it will extend the deadline for filing country-by-country reports of multinationals for fiscal years ending in 2016. The deadline has been extended from December 31 to February 28, 2018, due to technical difficulties associated with the electronic filing system. Irish Tax and Customs . . .
Irish chartered accountant JP Canavan discusses Ireland’s decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses a Trump administration executive order, issued last Friday, mandating the review of tax regulations, noting that those hoping the order will lead to the repeal of US earnings stripping and/or inversion tax regulations may wind up disappointed . . . .
Davide Anghileri of the University of Lausanne discusses OECD tax guidance, released April 6, which further clarifies the country-by-country reporting rules for large multinational groups . . .
Multinationals, particularly the largest firms, take advantage of profit shifting to low tax rate countries, mismatches between country tax systems, and preferential tax regimes to significantly lower their tax bills, though countries that strengthen their antiavoidance laws may be able . . .
Hong Kong’s Inland Revenue Department on December 22 issued more guidance on country-by-country reporting for large multinationals, including . . .
The EU Commission has today released a proposed directive designed to strengthen existing mechanisms to resolve tax disputes between EU countries that result in double . . .
UK tax professional, Tim Law, discusses the implications of a law passed yesterday that gives the government power to require public country-by-country reporting by multinationals . . .
The EU Commission today published a non-confidential version of its decision that Belgium’s excess profits tax scheme is illegal under EU State aid rules. The Commission’s decision, first announced in a press release last . . .
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