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Americas
EU proposal to halt multinational tax avoidance through third-country hybrid mismatches stalls
EU finance ministers, during an ECOFIN meeting of the Council of the EU held December 6, were unable to reach agreement on new hybrid mismatch rules designed to prevent multinationals from avoiding tax by exploiting differences between the tax systems of EU and non-EU countries. The ministers disagreed with a Dutch proposal to extend the effective date of the rules and a UK proposal. . .
Americas
India, US resolve 108 more cross-border tax disputes, agree to first bilateral APA
India and US tax officials have resolved 108 mutual agreement procedure (MAP) tax disputes and have reached agreement on the their first bilateral advance pricing agreement (APA), India’s Central Board of Direct . . .
Europe
Ireland adds time limits to bilateral advance pricing agreements but not other tax rulings
Irish Revenue has updated its tax manual to provide for strict time limits on the duration of bilateral advance pricing agreements (APAs) signed with other nations, but has declined to specify that any firm limits will be imposed on tax rulings granted to large taxpayers that seek confirmation of the tax treatment . . .
Americas
Americas
US IRS issues final country-by-country reporting regulations, rules permitting voluntary filing forthcoming
The US IRS today issued final regulations requiring large US parented mulitnational corporations to file annual country-by-country (CbC) reports consistent with OECD/G20 base erosion profit shifting (BEPS) project guidance, though taxpayers that wish to file voluntary reports for the 2016 tax year with the IRS will . . .
Americas
Bermuda signs agreement for exchange of country-by-country tax reports
Bermuda has become the 33rd signatory to a multilateral agreement setting out the parameters for the automatic exchange between tax administrations. . . .
Americas
Asia-Pacific
Americas
Americas
Asia-Pacific
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Europe
Asia-Pacific
Europe
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Americas
Duff & Phelps forms alliance with BaseFirma
BaseFirma, an international transfer pricing advisory firm with a major presence in Latin America, has joined Duff & Phelps’ Transfer Pricing Alliance, Duff & Phelps announced . . .
Asia-Pacific
Council of the European Union
Americas
Africa
Russia, Malta, Mauritius, Hungary, Gabon, Indonesia, Lithuania sign tax agreement on exchange of country-by-country reports
In an effort to provide their tax administrations with tools to combat corporate tax avoidance through transfer pricing, officials from 7 more countries have signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large . . .
Asia-Pacific
Updated UN manual reveals India’s transfer pricing positions
Bhavik Timbadia and Hussain Sunel of BMR & Associates LLP discuss the newly revised draft UN Practical Manual on Transfer Pricing for Developing Countries, focusing on the India chapter, which reveals Indian tax authorities’ current transfer pricing positions, including some surprising views on low value adding intra-group services . . .
Europe
Brazil
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
Austria
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OECD proposes conforming amendments to transfer pricing guidelines on business restructuring
The OECD on July 4 published proposed amendments to Chapter IX of the transfer pricing guidelines dealing with business restructuring to conform the guidance to recent changes made to other chapters on account. . .
Europe
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Transfer pricing guidelines should be interpreted consistently with BEPS changes, OECD says
Countries that integrate the OECD transfer pricing guidelines into their national laws should now begin to apply not only the recently approved OECD/G20 base erosion profit shifting (BEPS) plan transfer pricing changes, but should also interpret all . . .
Asia-Pacific
Australia weighs adoption of new OECD BEPS transfer pricing standards
The Australian Treasury on February 11 opened a consultation on whether Australia should adopt into law final OECD/G20 base erosion profit shifting (BEPS) transfer pricing . . .
Americas
Europe
Americas
CIAT-SECO partnership strengthens Latin American and Caribbean tax administrations
Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium, discuss recent activities of the Inter-American Center of Tax Administrations (CIAT) and the State Secretariat for Economic Affairs of the Swiss Government (SECO) to assist tax administrations in Bolivia, El Salvador, Guatemala, Guyana, Honduras, and Nicaragua with transfer pricing and other issues . . .
Africa
