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Switzerland seeks automatic exchange of tax information with 41 more countries
Switzerland has decided to pursue automatic exchange of financial account information arrangements with 41 more countries, writes Davide Anghileri of the University of Lausanne . . .
Europe
German guidance clarifies withholding tax on cross-border software, databases
International tax attorney Ninja-Antonia Reggelin discusses German guidance issued May 17 detailing the limited tax liability and source taxation of cross-border transfers of software and databases . . .
Featured News
2017 UN transfer pricing manual released, changes approved for model tax treaty
The UN’s Committee of Experts on International Cooperation in Tax Matters (UN Committee), during meetings held last week, released its revised and updated 2017 United Nations Practical Manual on Transfer Pricing for Developing . . .
Europe
Europe
Europe
Italy’s Supreme Court rules French holding company has sufficient substance for tax purposes
Davide Anghileri of the University of Lausanne discusses a recent decision of Italy’s Supreme Court which addresses the level of substance that a holding company must have to ensure that it is respected for purposes of obtaining a reduced rate of withholding tax under a tax treaty or for the application of the EU parent-subsidiary directive or interest and royalties directive . . .
Multinational
Asia-Pacific
Americas
Americas
Switzerland weighs expansion of automatic exchange of tax information to 20 more countries
Davide Anghileri of the University of Lausanne discusses Switzerland’s decision to launch a consultation on automatic exchange of information with 20 more countries . . .
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OECD: peer review for BEPS minimum standards released
The OECD today released documents to implement peer review of countries’ compliance with minimum standards devised under OECD/G20 base erosion and profit shifting (BEPS) Action 13, dealing with country-by-country reporting, and . . .
Australia
Australian tax agency offers multinationals guidance on tax risk management and governance
Davide Anghileri of the University of Lausanne writes about Australian Taxation Office guidance published January 27 designed to help foreign multinationals and other taxpayers understand the ATO’s views on what better tax corporate governance practices look like so companies can develop or improve their own tax governance and internal control framework . . .
Asia-Pacific
Japan and Lavia sign first tax treaty, text available
The governments of Japan and Latvia today signed a their first tax treaty, Japan’s Ministry of Finance has announced. The agreement, signed in Tokyo, would exempt royalties . . .
Asia-Pacific
Japan, Lithuania initial draft tax treaty
Japan and Lithuania have agreed in principle to a tax treaty, Japan’s Ministry of Finance . . .
Albania
Swiss tax treaty protocols with Norway, Albania enter into force
Switzerland’s Federal Council has today announced that tax treaty protocols with Albania and Norway. . .
Europe
France: public county-by-country reporting declared unconstitutional
The French Constitutional Council, December 8, ruled that sections of a law establishing public country-by-country reporting by multinationals are contrary to the Constitution, writes Davide Anghileri of the University of Lausanne . . .
Europe
UK releases draft legislation to limit interest deductions of large corporations
The UK government, on December 5, published draft clauses for a tax law that will limit the interest deductions of large corporations, to be included in the 2017 . . .
Americas
US, Mexico agree to transfer pricing framework for maquiladoras
The US IRS today announced agreement with Mexico on a transfer pricing framework for US multinational enterprises that have maquiladora operations which, if applied in . . .
Europe
Americas
Asia-Pacific
Israel proposes significant tax breaks to attract multinational corporation investment
Professor Rifat Azam discusses a draft Israeli proposal that offers big tax incentives to large multinationals that invest in Israel, particularity IP and knowledge-based investments . . .
Asia-Pacific
Australia steps up effort to combat corporate tax avoidance through offshore hubs, other schemes
The Australian Taxation Office (ATO) has intensified its efforts to crack down on multinational corporation tax avoidance, launching a consultation on the aggressive use of offshore hub structures, and issuing taxpayer alerts on offshore permanent establishments . . .
Europe
Africa
South African tax bill amends hybrid instrument rules, eliminates planned withholding on service fees
Peter Dachs of ENSafrica, Cape Town, discusses proposed revisions to South Africa’s tax law, released 8 July, that would reverse the planned introduction of withholding tax on service fees and that would modify the tax treatment of hybrid debt, share incentive schemes, and trusts that provide interest-free loans . . .
Americas
Europe
Draft German tax law adopts low threshold for transfer pricing master file, combats MNE tax avoidance
Tax specialist, Ninja-Antonia Reggelin, discusses a proposed new German tax law to combat multinational profit shifting, which includes implementation of transfer pricing documentation and country-by-country reporting and exchange of tax rulings, as well as several other measures. . .
