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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 . . .
Americas
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 . . .
Multinational
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 . . .
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New Zealand issues withholding tax rules for interest paid to related foreign lenders
New Zealand’s Inland Revenue on April 11 issued a special report providing guidance on new withholding tax rules for interest paid to related-party foreign lenders. Changes to these rules were made in the . . .
Asia-Pacific
Asia-Pacific
Hong Kong’s budget 2017–2018 tax proposals: more of the same, reheated
Stefano Mariani and Calvin Ng of Deacons provide a comprehensive analysis of the tax proposals in Hong Kong’s budget 2017–2018, released today, which the authors argue do little to promote Hong-Kong’s long-term competitiveness . . .
Americas
Eli Miller appointed US Treasury Chief of Staff
Eli Miller will serve as US Treasury Chief of Staff, newly appointed US Secretary of the Treasury, Steven T. Mnuchin, announced . . .
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 . . .
Americas
Europe
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 . . .
Asia-Pacific
Asia-Pacific
Singapore-Laos tax treaty enters into force
A new tax treaty between Singapore and Laos entered into force on November 11, Singapore’s Inland Revenue . . .
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 . . .
Belgium
The coming Belgian innovation income deduction: what to expect from the renewed R&D incentive
Daniel Garabedian and Steven Peeters of Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels, discuss in detail the expected features of the Belgian government’s planned innovation income deduction regime, which would replace the patent income deduction regime . . .
Asia-Pacific
Hong Kong, Belarus negotiating tax treaty
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus have commenced . . .
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 . . .
Americas
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
. . .
Asia-Pacific
Featured News
G20 ministers support plan to label countries that don’t share tax information as “non-cooperative”
G20 finance ministers and central bank governors, during their July 23–24 meeting in Chengdu, China, approved a plan that sets out objective criteria to be used to label countries as “non-cooperative” for tax transparency . . .
Denmark
Americas
Japan and Panama to negotiate tax information exchange agreement
The Japanese government has today announced that it will begin negotiations with Panama for a new. . .
Europe
UK consults on proposal to limit tax deductibility of corporate interest expense
As a part of its effort to address aggressive tax planning by large multinational groups, the UK government on May 12 launched a consultation on a proposal to introduce rules restricting interest . . .
Europe
German lawmakers weigh proposal to curb tax avoidance through cross-border dividend arbitrage
Tax specialist, Ninja-Antonia Reggelin, discusses Monday’s German Parliament committee hearing on the proposed reform of the investment tax law, including measures to address tax avoidance in the German banking sector through dividend arbitrage. . .
Africa
New protocol allows India to tax capital gains from sales by Mauritius residents of Indian company stock
India and Mauritius today signed a protocol to their 1983 tax treaty, revising the tax treatment of capital gains on sales by Mauritius residents of . . .
UPDATE: Text of the India/Mauritius protocol published: The text of the new protocl has been published on the Mauritius goverment website. See: Protocol.
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
Jersey signs tax treaty with United Arab Emirates
Jersey has signed a tax treaty with the United Arab Emirates, the goverment of Jersey announced April 21 . . .
Americas
US tax rules would curb inversions through earnings stripping limits, stopping serial inversions
The US Treasury today announced a package of tax rules designed to discourage corporate inversions, including measures that restrict earnings stripping . . .
Asia-Pacific
Singapore budget 2016 includes tax breaks for SMEs: Deloitte→
See: Deloitte. More: EY. Original sources: IRAS – Budget 2016 – Overview of Tax Changes, MOF – Budget 2016.
Asia-Pacific
Switzerland and South Korea agree to establish automatic exchange of information
Switzerland and South Korea have agreed to work toward implementing automatic exchange of information (AEOI) in tax matters on a reciprocal basis in accordance with the OECD common . . .
