New Zealand intends to introduce hybrid mismatch rules and will consult on new rules to prevent multinational corporations from stripping profits out of the country through excessive. . .
Singapore today announced that it will participate in the OECD/G20 base erosion profit shifting (BEPS) plan, adopting BEPS minimum standards, including country-by country. . .
The EU Commission today published the non-confidential version of its decision concluding that an advance pricing agreement (APA) granted to a Fiat subsidiary by Luxembourg is illegal . . .
Liechtenstein’s government on March 4 announced that it has instructed its tax authority to prepare a consultation report on implementing tax measures in the . . .
The US IRS today confirmed that, beginning February 16, the US competent authority will accept applications for Indian advance pricing agreements (APAs), citing. . .
Eugene Lim of Providence Law Asia LLC discusses new updates to Singapore transfer pricing guidance, issued February 23, setting out enhancements to the arm’s length principle, adding new transfer pricing documentation requirements, and granting new powers of the Comptroller of Income Tax to make transfer pricing adjustments and impose surcharges and penalties for non-compliance . . .
Yoshio Uehara and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cía., Mexico City, discuss new Mexican provisions allowing for transfer pricing adjustments as of January 1 . . .
Cyprus’ Ministry of Finance on December 22 announced that it will issue a decree setting out the requirements for country-by-country reporting . . .
Goodmans LLP tax attorney, Kabir Jamal, provides an analysis of the international tax proposals in the Canadian government’s draft tax bill, issued July 29, including measures that address foreign exchange gains on foreign-currency debt, back-to-back loan and royalty arrangements, and country-by-country reporting . . . .
The EU Commission on June 3 released a working paper identifying several categories of Member State transfer pricing rulings that raise potential State aid concerns because they sanction profit allocations. . .
The Romanian government, on June 2, announced that it will join countries working on the next phase of the OECD/G20 base erosion and profit shifting (BEPS) project as an associate, developing standards and monitoring the implementation of the BEPS . . .
As expected, the EU Commission will need to defend in court its contention that advance pricing agreements (APAs) granted to a Starbucks subsidiary by the Netherlands and to a Fiat subsidiary by Luxembourg . . .
Francisco Lisboa Moreira, a partner with Bocater, Carmargo, Costa e Silva, Rodrigues, São Paulo, provides an update of recent Brazilian tax developments of interest to MNEs, discussing new Brazilian transfer pricing guidance and the Brazilian Congress’s approval of protocol to the Brazil-Denmark tax treaty . . .
India transfer pricing and tax litigator Ajit Jain discusses new transfer pricing rules providing for secondary adjustments . . .
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