Americas
Transfer Pricing
Asia-Pacific
Americas
US, Canada sign competent authority agreement for exchange country-by-country tax reports
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
Asia-Pacific
Despite progress, problems loom for India’s APA program
Mumbai chartered accountant, Ajit Jain, discusses progress and problems with India’s advance pricing agreement (APA) program . . .
Asia-Pacific
Indian tax authority signs APAs at a quick pace but backlog grows, report shows
Indian tax officials signed a record number of advance pricing agreements (APAs) in fiscal year 2016–17; nonetheless, India’s backlog of unresolved APA cases increased during the . . .
Europe
Italy: transfer pricing and patent box bill becomes law
Davide Anghileri of the University of Lausanne discusses an Italian law adopted April 24 that modifies Italy’s transfer pricing provisions to make them in-line with the OECD’s arm’s length principle, adds corresponding adjustments to Italian tax law, and updates the list of intellectual property that can qualify for the patent box regime . . .
Asia-Pacific
India, Kazakhstan tax treaty protocol signed
India and Kazakhstan have signed a protocol to amend their 1996 tax treaty, the
Indian government announced today. The new protocol . . .
Africa
Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance
Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat . . .
Americas
New US subpart F tax regulations address foreign partnerships, active rents and royalties exception
Amanda Varma and Brigid Kelly of Steptoe & Johnson LLP, Washington, discuss final regulations released November 2 that clarify various issues arising under subpart F related concerning foreign partnerships and active rents and royalties . . .
Americas
Indian tax official sees expanded role for BEPS inclusive framework, addresses transfer pricing local file
The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS . . .
Featured News
OECD releases comments on draft tax guidance relating to profit splits, permanent establishment
The OECD today released 107 comment letters, mostly from business representatives, that respond to two OECD discussion drafts providing for common tax rules to be used to allocate multinational corporation profits among the countries in which they operate. Fifty-five comment letters relate to the OECD’s proposed revisions to its transfer pricing . . .
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OECD releases 14 comments letters on conforming amendments to transfer pricing guidance
The OECD on August 24 released letters from 14 organizations responding to its request for comments on draft conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines titled
. . .
Denmark
Asia-Pacific
Australia’s tax office warns MNEs that particular transactions will be examined for tax avoidance
The Australian Taxation office (ATO) has today released four alerts, warning multinationals that specified transactions will be heavily scrutinized for tax . . .
Asia-Pacific
Europe
Asia-Pacific
Belgium
Americas
Americas
Asia-Pacific
Multinational
Asia-Pacific
Americas
Featured News
Europe
Belgium
EU Commission calls out harmful tax practices in Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta, Netherlands
The EU Commission took tentative steps toward reducing harmful tax competition among EU member countries today, publishing European Semester country reports that identify seven EU countries as potentially facilitating tax avoidance by multinationals. The Commission today also released a taxation paper detailing economic evidence that suggests that particular tax avoidance structures , , ,
Americas
Companies face setback in challenge to District of Columbia’s use of Chainbridge transfer pricing method
Mark Nachbar and Mary Bernard of Ryan, LLC note the release of a surprising January 26 ruling in actions, brought by Hess, Exxon, and Shell, challenging the District of Columbia’s use of transfer pricing software developed by Chainbridge Software to assess millions in tax liabilities against them . . .
Americas
Multinational
Europe
Asia-Pacific
India revises transfer pricing safe harbors providing tax relief to multinationals
India transfer pricing specialist Ajit Jain discusses the government’s June 7 decision to add a new transfer pricing safe harbor for low-value adding intragroup services and reduce existing safe harbor margins for knowledge process outsourcing services, contract research and development services, and other services.. . . .
Featured News
The new OECD/G20 guidance aligning transfer pricing outcomes with value creation: upending international contract law
US international transfer pricing attorneys Robert Feinschreiber and Margaret Kent discuss guidance developed during the OECD/G20 base erosion profit shifting (BEPS) project which applies transfer pricing concepts to contracts. . .
Multinational
Asia-Pacific
Singapore releases tax form for reporting related party transactions
Singapore’s Inland Revenue Service has today released a sample copy of tax form to be used by multinationals to report related party transactions. The form is designed to allow the tax agency to better assess transfer pricing . . .
Americas
Americas
Europe
EU proposal requiring multinationals to publicly disclose tax information disputed by business, NGOs
Large multinational corporations operating in Europe would be required to publicly disclose tax information on a country-by-country basis under an EU Commission proposal, unveiled April 12, which is already drawing criticism from both . . .
Americas
