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Asia-Pacific

Thailand studying new tax rules for internet and technology companies: Reuters→

September 26, 2016

See: Reuters.

Europe

OECD finalizing BEPS multilateral instrument, concerned about EU state aid tax probes

September 22, 2016

Officials are putting the finishing touches on the multilateral instrument (MLI) to implement the OECD/G20 base erosion profit shifting (BEPS) measures, keeping it on track to be finalized this fall, senior . . .

Asia-Pacific

Australian tax office issues 136 letters to multinationals warning of MAAL violations: Nassim Khadem / Sydney Morning Herald→

August 16, 2016

See: Sydney Morning Herald.

Africa

Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance

July 19, 2016

Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .

European finance ministers adopt anti-tax avoidance directive

July 12, 2016

The EU Economic and Financial Affairs Council (ECOFIN) today formally adopted without discussion the Anti-Tax Avoidance Directive (ATAD), designed to tackle multinational corporation tax . . .

Europe

Netherlands considers corporate rate cut: Janene Pieters / NL Times→

June 24, 2016

See: NL Times

G7 leaders pledge to steadily adopt BEPS international tax measures

May 31, 2016

Leaders of the G-7 nations of the US, UK, Canada, France, Japan, Germany, and Italy, following their meeting in Ise-Shima, Japan, vowed to “lead by example” by implementing the OECD/G20 base erosion profit shifting (BEPS) package in . . .

EU moving forward with tax haven blacklist: Francesco Guarascio / Reuters→

May 19, 2016

See: Reuters

Multinational

ICIJ publishes database of almost 214,000 offshore shell companies: ICIJ→

May 9, 2016

See: ICIJ.

Europe

Trial of “Lux Leaks” whistleblowers, journalist to begin in Luxembourg: Michele Sinner and Robert-Jan Bartunek / Reuters→

April 25, 2016

See: Reuters. More: France 24, The Guardian.

Americas

US IRS Appeals rules Delphi not liable for US tax on worldwide profits under inversion rules: Dustin Walsh / Crain’s Detroit Business→

April 14, 2016

See: Crain’s Detroit Business. More: SEC Form 8K (Streetinsider.com), Reuters, Wall Street Journal.

EU Commission expected to advance proposal allowing member states more freedom to set VAT rates: Ruth Berschens / Handelsblatt→

March 30, 2016

See: Handelsblatt. More: Financial Times.

Americas

Canadian budget adopts CbC reporting and exchange of tax rulings, restricts back-to-back loans and royalties: Stikeman Elliott→

March 23, 2016

See: Stikeman Elliott. More: Osler, Hoskin, & Harcourt , Aird & Berlis, EY. Original source: Budget.

G20 finance ministers endorse OECD plan to open BEPS project to all countries

February 29, 2016

G20 finance ministers, during their February 26–27 meeting in Shanghai, approved an OECD-developed plan to allow all countries to participate in the implementation of base erosion profit shifting (BEPS) . . .

Europe

EU expected to propose public country-by-country reporting of multinationals’ tax information

February 8, 2016

The European Commission will likely propose EU-wide legislation requiring large multinationals to publicly report their European profits and . . .

Belgium

Belgium may withdraw from EU financial transactions tax talks: Rebecca Christie / Bloomberg→

January 25, 2016

See: Bloomberg. More: Europe Online Magazine, The Brussels Times.

Americas

Tyco reaches tentative settlement with IRS in earnings stripping dispute: MarketWatch: Bob Tita / Marketwatch→

January 20, 2016

See: MarketWatch. More: Street Insider.

Europe

France’s digital tax may not comply with EU law on freedom of establishment, free competition: Out-Law→

March 14, 2019

Africa

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

January 31, 2019

The OECD has published a progress report detailing whether countries are meeting their commitments to . . .

Europe

Professors discuss German proposal for an internationally coordinated minimum tax on MNE profits: Johannes Becker & Joachim Englisch / Tax Justice Network→

January 16, 2019

Americas

New Brazil MAP guidance aids taxpayers seeking cross-border tax relief

January 3, 2019

Francisco Lisboa Moreira discusses Brazil’s new mutual agreement procedure (MAP) guidance, which aims to meet global standards . . .

Digital Economy

France to introduce “GAFA tax” on large internet and technology companies from January 1, giving up on EU digital tax deal: DW.com→

December 18, 2018

In early December, Economy Minister Bruno Le Maire said . . .

More: BBC News.

Americas

US foreign tax credit regs address TCJA changes

November 28, 2018

The US IRS and Treasury today issued key proposed regulations addressing the foreign tax credit for both businesses and individuals. The 312-page regulations . . .

Digital Economy

Not everyone’s cup of DST: five thoughts on the UK digital services tax consultation

November 15, 2018

Julian Feiner of Dentons, London, discusses the UK’s November 8 consultation on a proposed new digital services tax, identifying key takeaways from the paper . . .

Asia-Pacific

MNEs decry tax increase from new Vietnam rule limiting interest deduction to 20% EBITDA: Hanoitimes→

November 5, 2018

EU ministers agree to VAT fixes, new rules for electronic publications

October 2, 2018

EU finance ministers at their meeting today in Luxembourg agreed to fix several . . .

Asia-Pacific

Nepal committee formed to study signing tax treaty with UK, other nations: My Republica→

September 24, 2018

Belarus

UK-Belarus tax treaty enters into force

August 10, 2018

The UK-Belarus tax treaty, signed September 26, 2017, entered into force on July 27, the UK government . . .

Americas

Proposed US deemed repatriation regulations provide clarity but reject taxpayer suggestions

August 8, 2018

Friedemann Thomma and Lauren Keller of Venable LLP discuss comprehensive proposed regulations, released August 1, that address the Section 965 deemed repatriation “toll charge” imposed on US persons with foreign earnings accumulated offshore . . .

Americas

US Tax Court releases decision in Illinois Tool Works repatriation case

August 7, 2018

The US Tax Court on August 6 released its decision in Illinois Tool Works, sanctioning a US MNE’s strategy to repatriate foreign earnings held by . . .

Americas

US, Indonesia agree to exchange country-by-country data on multinationals to prevent tax avoidance

July 2, 2018

The US and Indonesia have signed a competent authority agreement providing for the exchange of country-by-country reporting data, US Treasury . . .

Americas

US imposes tariffs on EU, Canada, Mexico of 25 percent on imported steel, 10 percent on imported aluminum: Jeremy Diamond & Julia Horowitz / CNN Money→

May 31, 2018

Americas

Brazil signs key tax agreements with Singapore and Switzerland

May 23, 2018

Francisco Lisboa Moreira of Bichara Advogados, São Paulo, and Matheus de Moura Sena, of KPMG, Singapore, analyze new tax treaties signed by Brazil earlier this month with Singapore and Switzerland . . .

Switzerland shares private tax rulings with other nations for the first time

May 10, 2018

Switzerland’s Federal Tax Administration (FTA) on May 8 announced that for the first time it transmitted information on private tax rulings to partner states thus meeting its obligation of spontaneous exchange of information, writes Davide Anghileri, University of Lausanne . . .

Americas

Saint Lucia becomes 114th country to join “inclusive framework” countering multinational tax avoidance

May 9, 2018

The OECD has announced that Saint Lucia has joined the “Inclusive Framework on BEPS,” bringing the number of participating countries to 114. The OECD-led framework . . .

Americas

New IRS rules aim to prevent avoidance of transition tax on foreign subsidiary earnings

April 2, 2018

The US IRS today published rules designed to prevent US companies from avoiding the new transition tax on untaxed foreign subsidiary earnings, added last December in the Tax Cuts and Jobs Act. The guidance, Notice 2018-26, also . . .

EU Commission, by focusing on the low effective corporate tax rates of the largest digital firms, incorrectly concludes that digital firms pay too little tax, think tank concludes: Matthias Bauer / ECIPE→

March 20, 2018

Americas

US, Cayman Islands negotiating exchange of country-by-country reports on large multinationals

February 27, 2018

The US and the Cayman Islands are negotiating competent authority agreement for the bilateral exchange of country-by-country reports on large multinationals, the US IRS announced . . .

Asia-Pacific

India and Iran sign tax treaty

February 19, 2018

India and Iran today signed a new tax treaty in New Dehli, India’s Central Board of Direct Taxes . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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