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Council of the EU
Council expected to approve EU-wide tax dispute resolution system
The Economic and Financial Affairs Council is expected to approve a directive establishing an EU-wide system for resolving double taxation disputes at its meeting of October 10. Ministers will also hear a presentation by the Commission about its proposed strategy for digital taxation, aimed at . . .
Americas
Asia-Pacific
Europe
Americas
Asia-Pacific
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
Asia-Pacific
Lebanon, Kuwait, Turkey sign international tax agreements
Lebanon and Kuwait have signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, bringing total signatories to the agreement. . .
Cyprus
Cyprus to sign OECD multilateral treaty on tax avoidance, dispute resolution
Cyprus will sign the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting( MLI), Cyprus’s Ministry of Finance has announced . . .
G20
Asia-Pacific
Singapore agrees to automatic exchange of tax information with Belgium and Luxembourg
Singapore has signed agreements with Belgium and Luxembourg for the automatic exchange of financial account information, the Inland Revenue Authority of Singapore (IRAS) announced . . .
Americas
IRS tax regulations and the 1 for 2 Trump executive order
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, discusses President Trump’s executive order mandating that for every new regulation issued, two must be removed, noting that it will be very difficult to apply this order to US tax regulations . . .
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 . . .
Americas
Europe
France’s diverted profits tax ruled unconstitutional
France’s Constitutional Council on December 29 struck down France’s controversial diverted profits tax law, finding it unconstitutional, and also determined that changes to the financial transaction tax are constitutional, writes Davide Anghileri of the University of Lausanne, a contributing editor at MNE Tax . . .
Africa
Singapore-South Africa tax treaty enters into force
A new Singapore-South Africa tax treaty entered into force on December 16, Singapore’s Ministry of Finance . . .
Europe
UK Autumn Statement 2016: leaves little changed
UK tax professional Tim Law discusses Autumn Statement 2016, released today, focusing on tax changes for large business. . .
Europe
Americas
US IRS issues final and proposed tax regulations on US property held by CFCs involving partnerships
The US IRS today published final regulations (TD 9792) providing rules regarding US property held by a controlled foreign corporation (CFC) in connection with certain transactions . . .
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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 . . .
Africa
Africa
Singapore and Ethiopia sign tax treaty, text available
Singapore and Ethiopia signed a tax treaty on August 24, Singapore’s Inland . . .
Austria
Asia-Pacific
New Hong Kong, Russia tax treaty enters into force
A tax treaty signed by Hong Kong and Russia entered into force on July 29, Hong Kong’s Inland Revenue department has announced. The agreement will be in effect in Hong Kong for any tax year . . .
Europe
Netherlands and Switzerland agree on tax treatment of investment vehicles under tax treaty
Wiebe Dijkstra, Frank Pötgens, and Klaas Versteeg, of De Brauw Blackstone Westbroek, Amsterdam, analyze two mutual agreements recently concluded between the Netherlands and Switzerland concerning the taxation of collective investment vehicles, arguing that one of the agreements inappropriately prevents taxpayers from accessing the benefits of the Dutch-Swiss tax treaty . . .
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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. . .
