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China to offer key tax breaks to promote foreign investment
Richard Tan, a partner at Zhong Lun Law Firm, discusses the State Council’s new plan to promote foreign investment into China, presented August 16, which includes withholding tax deferral for reinvested dividends, an extension of the technological service enterprises tax incentive, and a new tax break for overseas income remitted back to China . . .
Council of the EU
Asia-Pacific
Americas
Trump budget advocates territorial tax system, omits border adjustment
US President Trump today released his first budget, presenting tax proposals that echo the principles that the Administration . . .
Europe
German tax law denying corporate loss carryforward is unconstitutional, court rules
A German court has struck down portions of a controversial law that denies tax loss carryforwards following a change of shareholders, ruling that the provisions are unconstitutional, writes international tax practitioner Ninja-Antonia Reggelin . . .
Featured News
OECD lists countries agreeing to country-by-country reporting exchange
The OECD today released an updated list of automatic exchange relationships established between tax authorities to implement country-by-country reporting under Action 13 of the OECD/G20 base erosion profit shifting (BEPS) plan. The OECD also announced activation of automatic . . .
Europe
Featured News
New UN extractives industry guidance note analyzes value chain for mining, oil and gas
US transfer pricing lawyers Robert Feinschreiber & Margaret Kent examine a guidance note, released last week by the UN’s Committee of Experts on International Cooperation in Tax Matters, which concerns transfer pricing issues associated with extractive industries, specifically mining and mineral extraction and oil and natural gas production . . .
Asia-Pacific
Europe
Switzerland: withholding tax exemption adopted to facilitate intragroup financing
Switzerland’s parliament, on March 10, approved a withholding tax exemption for intragroup interest payments, writes Davide Anghileri of the University of Lausanne. . .
Europe
EU Commission seeks public input on cooperation to prevent cross-border VAT fraud
The EU Commission today opened a public consultation to gather views on the functioning of administrative cooperation regarding value added tax (VAT) and regarding the fight. . . .
Asia-Pacific
Singapore budget includes IP regime: Inland Revenue Authority of Singapore→
See: Budget. *The budget will be analyzed in a forthcoming MNE Tax article.
Europe
EU proposals for public country-by-country reporting, CCCTB should be rejected, Irish finance minister says
Ireland’s Minister for Finance Michael Noonan today expressed opposition to EU Commission proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country reporting, arguing that both measures are counterproductive . . .
Americas
Fight brewing over effort to roll back US debt/equity tax regulations
US Democrats on the House Ways and Means Committee today urged their colleagues to oppose an effort to repeal the final Section 385 debt/equity . . .
Asia-Pacific
Australian government introduces diverted profits tax legislation: Parliament of Australia→
See: Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017; Diverted Profits Tax Bill 2017.
MNE Tax expects to publish an analysis of this development shortly.
Africa
Americas
Bermuda, Kazakhstan, Côte d’Ivoire join BEPS group fighting cross-border tax avoidance
Bermuda, Kazakhstan, and Côte d’Ivoire have joined the “Inclusive Framework on BEPS,” to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . .
Featured News
World Bank publishes transfer pricing handbook for developing countries
Joel Cooper of DLA Piper discusses a new World Bank handbook designed to assist developing country tax administrations with the implementation of transfer pricing rules. . .
Europe
Denmark
EU court to hear challenge to Denmark’s withholding tax on dividends paid to foreign investment funds
The European Court of Justice has published a reference for a Danish case (C-480/16) in the . . .
Asia-Pacific
Australia: country-by-country reporting exemption guidance offers relief to MNEs
The Australian Taxation Office (ATO) has issued guidance for multinational groups on how to apply for an exemption from the obligation to provide some or all of the information in required tax statements known as . . .
Asia-Pacific
Europe
EU Advocate General approves directive excluding digital publications supplied electronically from reduced VAT
The EU VAT Directive is valid in so far as it applies a reduced rate of tax only to printed books, newspapers and periodicals, as well as to digital books which are supplied by means of a physical medium, as opposed to digital publications supplied electronically . . .
Europe
Jacques Mestoudjian joins Eversheds’ Paris office
Jacques Mestoudjian has joined Eversheds as a partner in its Paris office . . .
Americas
Asia-Pacific
Featured News
OECD releases discussion drafts on attribution of MNE profits to permanent establishments and profit splits
The OECD today released two discussion drafts on international tax standards that deal with allocating multinational corporation profits between tax jurisdictions: guidance on the attribution of profits to permanent establishments (PEs) and proposed revisions to guidance on profit splits under the OECD . . .
Austria
