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.. . . .
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. . .
Australia has assessed seven multinational corporations with tax liabilities totaling AUS $2.9 billion (~USD 2.2 billion), Treasurer Scott Morrison and Minister . . .
Taiwan’s taxation office announced Monday that foreign enterprises and other entities from specified countries that have no fixed place of business in Taiwan but engage in. . .
Corporate tax reform III was rejected by popular referendum today, with 59.1 percent of the population voting against the Swiss government proposal, writes MNE Tax contributing editor, Davide Anghileri, of the University of Lausanne . . .
Japan and Austria signed a new tax treaty on January 30 to update their 1963 agreement, Japan’s . . .
The US IRS on December 13 published final tax regulations (T.D. 9796) under sections 6038A and 7701 that require wholly foreign-owned domestic disregarded entities to be treated as a domestic corporations, separate from their owners . . .
Davide Anghileri of the University of Lausanne discusses Switzerland and India’s November 22 signing of a joint declaration on the introduction of automatic exchange of information in tax matters . . .
Davide Anghileri of the University of Lausanne discusses Switzerland and Austria’s November 11 agreement to terminate their withholding tax agreement . . .
EU finance ministers today agreed to criteria to be used to identify non-EU countries as candidates for an EU-wide tax haven blacklist which could result in countries that have low or even zero corporate. . .
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 . . .
Switzerland and Latvia today signed a protocol to their 2002 double taxation agreement, Switzerland’s Federal Council has . . .
The text of the Luxembourg-Ukraine tax treaty protocol, signed September 30, has been released by Luxembourg’s tax administration. The treaty, which would amend the countries’ 1997 tax treaty, provides for a reduction in the . . .
The Australian government on September 28 released a draft report suggesting ways to improve the country’s research and development (R&D) tax incentive . . .
Hong Kong’s Inland Revenue Department announced September 9 that tax legislation that provides for automatic exchange of financial account information (AEOI) entered into effect . . .
Japan and Estonia will begin negotiations for a tax treaty, Japan’s Ministry of Finance announced . . .
International tax experts, Wiebe Dijkstra and Klaas Versteeg of De Brauw Blackstone Westbroek, Amsterdam, analyze a proposed Netherlands tax law that would tighten rules designed to prevent excessive leveraging of acquisitions of Dutch companies by private equity investors . . .
The OECD on July 4 released 33 comment letters received in response to its discussion draft on the development of a multilateral instrument to implement the tax treaty provisions in the final OECD/G20 base erosion profit shifting (BEPS) plan reports. All the comment letters released, except for one, submitted by the BEPS Monitoring . . .
Kabir Jamal, an attorney with Goodmans LLP, Toronto, discusses statements made by Canadian Revenue Agency officials at a conference last week announcing the agency’s decision to classify Florida and Delaware LLPs and LLLPs as corporations for income tax purposes . . .
Liechtenstein and India may soon negotiate. . .
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 . . .
The international tax proposals in President Obama’s fiscal year 2017 budget, released February 9, look a lot like the proposals in last year’s budget. The administration has again proposed a one-time 14 percent tax on . . .
Gian Luca Nieddu of Hager & Partners, Milan area, discusses a recent Italian Supreme Court decision rejecting an Italian corporation’s request for reimbursement of withholding taxes paid on dividends distributed to its Luxembourg parent; the author argues that the opinion is based on faulty reasoning . . .
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