Multinational
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Europe
UK proposes tax on royalties paid to low tax countries, hitting multinational digital businesses
UK Chancellor Philip Hammond in his Autumn Budget speech today proposed a new tax on multinational firms designed to primarily reach firms in the digital sector. The UK government also published a position paper outlining its thinking on the taxation of digital firms. Following consultation, the UK government . . .
Asia-Pacific
India’s final transfer pricing master file rules retain unique flavor
Jitendra Jain, Executive Director, PricewaterhouseCoopers, discusses final Indian rules for multinational taxpayers, released October 31, on the implementation of the transfer pricing master file and country-by-country report, noting that important changes were made to the earlier, draft version of the guidance. . .
Americas
Americas
OECD publishes peer review reports on tax dispute resolution in US, Belgium, Canada, Netherlands, Switzerland, UK
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
Africa
Americas
Europe
Asia-Pacific
Featured News
OECD releases revised discussion drafts on attribution of profits to PEs, profit splits
The OECD today released revised draft guidance on the attribution of profits to permanent establishments (PEs) as well as revised draft transfer pricing guidance on profits splits. Both discussion drafts replace earlier drafts . . .
Council of the EU
EU agrees to mandatory binding arbitration of tax disputes
Davide Anghileri of the University of Lausanne discusses an ECOFIN deal, reached May 23, for a directive that will create a new system for resolving double taxation disputes between the EU States; he also provides an update of EU discussions on adopting a common corporate tax base (CCTB) . . .
Europe
Asia-Pacific
Australia budget 2017 hits hybrid regulatory capital tax abuse, extends MAAL
In a further effort to curtail tax avoidance by multinationals, Australia will introduce hybrid mismatch provisions applicable to banks and insurance companies and tighten . . .
Asia-Pacific
Americas
Cayman Islands, Belize to adopt BEPS international tax standards
The Cayman Islands and Belize have become members of the “Inclusive Framework on BEPS,” the OECD announced today. The inclusive framework is a group of countries that have pledged to put into place minimum standards aimed at preventing tax avoidance and improving . . .
Europe
Americas
Asia-Pacific
Americas
Americas
Asia-Pacific
Americas
US finalizes regs on outbound transfers of foreign goodwill
The US IRS has released final regulations (TD 9803) under section 367 which eliminate the favorable tax treatment of outbound transfers . . .
Europe
Ireland releases Q&As on country-by-country reporting for multinationals
Irish Revenue has released a set of frequently asked questions relating to the country-by-country reporting requirements for multinationals under Irish legislation . . .
Asia-Pacific
Draft Australia diverted profits tax legislation released for public comment
The Australian government today released draft diverted profits tax legislation, designed to stop large multinational businesses from artificially . . .
Africa
Portugal must grant company at least partial tax deduction for dividends received from Tunisian or Lebanese subsidiaries, EU court rules
Davide Anghileri, a lecturer at the University of Lausanne, discusses a Court of Justice of the European Union decision which concludes that Portugal’s current practice of denying Portuguese companies a deduction for intercompany dividends received from Tunisian or Lebanese subsidiaries violates EU law . . .
Europe
EU Commission survey addresses tax advisors, intermediaries that aid tax evasion and avoidance
The European Commission has today launched a public consultation on whether the EU should take action to create disincentives for tax advisors and other intermediaries that help taxpayers . . .
Americas
The final debt-equity regulations: planning to comply
Robert M. Gordon and Jennifer Crawford of True Partners Consulting LLC discuss the final US debt-equity regulations, focusing on the regs’ new documentation requirements for related party debt . . .
Andorra
Andorra becomes 40th non-OECD/G20 country to join “inclusive framework” for BEPS implementation
Andorra has become the 40th country that is neither an OECD nor G20 member to join what is known as the inclusive framework for BEPS implementation, a group of countries that have pledged to adopt measures, designed by the OECD and G20 in the base. . .
Asia-Pacific
Singapore issues country-by-country reporting guide assist MNEs
Singapore’s tax authority has prepared a tax guide addressing how large multinationals can fulfill the obligation to prepare and submit country-by-county reports . . .
Europe
Italy: new circular outlines tax deductibility of blacklist costs
Italy’s tax authorities on September 26 issued a circular clarifying new rules on the deductibility of costs associated with transactions between Italian resident individuals or entities and businesses operating in blacklisted tax haven countries, writes guest author, Davide Anghileri . . .
Asia-Pacific
Featured News
OECD draft addresses multinational banks and insurance companies that take excessive interest deductions
The OECD today issued draft rules to be used by countries that seek to prevent multinational banks and insurance companies from avoiding tax through excessive interest . . .
Featured News
OECD sets criteria for labeling countries as “non-cooperative” tax jurisdictions, previews coming tax guidance
The OECD has devised proposed criteria for determining if a country is a “non-cooperative” tax jurisdiction, an official said during a July 12 OECD webinar. OECD officials also discussed plans to release further tax and transfer pricing . . .
Featured News
New OECD country-by-country reporting guidance provides for voluntary filing
The OECD today issued further guidance implementing the new transfer pricing documentation and country-by-country (CbC) standards of action 13 the OECD/G20 base erosion profit shifting plan. The guidance is designed to ensure consistent implementation . . .
Multinational
Americas
Americas
Medtronic wins transfer pricing dispute in Tax Court
Medical device manufacturer Medtronic on June 9 won its transfer pricing dispute with the IRS in Tax Court, beating back the IRS’s claim that the medical device manufacturer should have reported increased US royalty payments and 2005 and 2006 from a related Puerto Rico . . .
Asia-Pacific
Asia-Pacific
