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Latest

Asia-Pacific

Payments by Google India were royalties subject to withholding tax, tribunal rules

October 30, 2017

Mansi Seth and Joachim Saldanha of Nishith Desai Associates discuss an October 24 Indian tribunal decision which held that payments made by Google India to Google Ireland for marketing and distribution of online ad space through the Google’s AdWords program were royalty payments subject to withholding tax . . .

Europe

UK, Ukraine tax treaty protocol signed, text available

October 24, 2017

The text is available of a protocol to the UK-Ukraine tax treaty, signed by representatives of both countries on October 9. The protocol, which is not yet in force, would amend a double tax treaty signed . . .

Europe

13 of Ireland’s top 100 companies pay tax at 1% rate: The Irish Times→

September 29, 2017
Europe

UK Finance Bill draft clauses published: EY→

September 17, 2017
No Picture
Europe

EU to debate change to PE definition to impose tax on large online firms: Reuters→

September 7, 2017
Europe

Bevers, Halprin, Reinoud, Marnix join Dentons Boekel’s new Dutch tax practice

August 28, 2017

Jurjen Bevers, Paul Halprin, Heico Reinoud, and Marnix Veldhuijzen, all formerly with Baker and McKenzie, have joined Dentons Boekel’s new tax team . . .

Featured News

UN selects members of influential international tax committee

August 28, 2017

The United Nations has announced the appointment of 25 individuals to serve four year terms on a key committee responsible for UN international tax and transfer pricing . . .

Europe

Russia removes Korea, BVI from tax blacklist: KPMG→

August 15, 2017
Americas

US tax planning after the MLI: Jeffrey L. Rubinger & Summer Ayers LePree / Taxes Without Borders→

June 28, 2017
Africa

Nigeria committee to investigate perceived abuse of pioneer status tax incentive: Deloitte→

May 22, 2017
Featured News

G7 finance ministers open to tackling tax challenges of digitalization

May 15, 2017

G7 finance ministers and central bank governors, following their May 12–13 meeting in Bari, Italy, said they may be able to back policy measures designed to ensure that tax challenges associated with the digitalization of . . .

Americas

Illinois bill would forbid state contracts with expatriated residents of 38 ‘tax havens’ including Luxembourg: Brendan Bakala / Illinois Policy→

April 10, 2017
Europe

Luxembourg to support Ireland’s appeal in Apple State aid tax case: Joe Brennan / The Irish Times→

March 29, 2017

See: The Irish Times.

Asia-Pacific

Japan, Russia negotiate tax treaty

March 27, 2017

Japan and Russia have begun negotiations to amend their tax treaty, Japan’s Ministry of Finance has announced. The . . .

Americas

Trump’s address to Congress offers few details on tax reform: Steptoe & Johnson→

March 1, 2017

See: Steptoe & Johnson

Asia-Pacific

Hong Kong, Pakistan sign tax treaty

February 21, 2017

Hong Kong and Pakistan signed a tax treaty on February 17, the Hong Kong government has announced. This is the 37th tax treaty signed by . . .

No Picture
Austria

Austrian, German dispute over taxation of profit-participation certificates to be considered by European Court

February 8, 2017

The European Court of Justice has published a reference for an Austrian case (Case C-648/15) concerning whether Austria or Germany can tax profit-participation certificates (Genussscheine). Austria claims that the Court should hold that . . .

Multinational

Authors discuss pros and cons of destination-based cash flow taxation: Auerbach, Devereux, Keen, Vella / Oxford University Centre for Business Taxation→

January 27, 2017

See: Paper.

Asia-Pacific

India issues tax guidance on MNE place of effective management: Central Board of Direct Taxes→

January 27, 2017

See: Central Board of Direct Taxes.

*This guidance will be analyzed in a forthcoming MNE Tax article.  

Featured News

Transfer pricing toolkit for developing countries jointly released by IMF, OECD, UN, Word Bank Group

January 25, 2017

The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN, and World Bank Group – on January 24 released a draft toolkit addressing ways that emerging economies can overcome lack of transfer pricing comparable data . . .

What's New

Japan-Chile tax treaty enters into force

January 5, 2017

A tax treaty between Japan and Chile signed January 21, 2016, has entered into force, the Japanese government . . .

No Picture
Americas

Canada, Switzerland exchange notes on automatic exchange of information

December 26, 2016

Canada and Switzerland on December 23 exchanged notes for automatic exchange of information in tax . . .

No Picture
Europe

EU public country-by-country reporting compromise offered

December 21, 2016

On December 19 the EU presidency released a proposal for the public disclosure of tax information by multinational groups, writes Davide Anghileri of the University of Lausanne . . .

No Picture
Europe

Apple may lose EU State aid dispute, tax experts say

December 20, 2016

The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company’s subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .

Europe

Spain limits large corporation NOLs, foreign tax credits: PWC→

December 7, 2016

See: PWC.

Europe

Professor calls for renewed investigation of Lux Leaks scandal: Omri Y. Marian / SSRN→

November 3, 2016

See: SSRN.

Europe

Guidance on Northern Ireland’s corporate tax regime published

September 27, 2016

The UK tax authority on September 26 published draft guidance on the operation of Northern Ireland’s corporation tax regime, setting out . . .

Asia-Pacific

Chevron case reveals failure of OECD rules to aid pricing of intragroup loans, Australian professors say: Richard J. Vann, Graeme S. Cooper / SSRN→

August 23, 2016

See: SSRN.

Americas

US IRS adds two new international tax projects to priority guidance list

August 15, 2016

The US IRS on August 15 released its list of priority tax guidance projects for 2016-17, revealing that the agency has decided to work on issuing guidance in the areas of foreign currency contracts and country-by-country . . .

Cyprus

Cyprus and Jersey sign tax treaty

July 18, 2016

The governments of Cyprus and Jersey signed a comprehensive tax treaty on July 11, the two governments . . .

Europe

UK to propose slashing corporate rate below 15 percent to contain Brexit fallout: BBC News→

July 4, 2016

See: BBC News. More: Bloomberg, The Guardian.

Armenia

Germany, Armenia sign tax treaty: Akholi News→

June 30, 2016

See:  Akholi News.

Europe

Germany’s Martin Kreienbaum to chair OECD Committee on Fiscal Affairs

June 30, 2016

Martin Kreienbaum, Director General of International Taxation at the Federal Ministry of Finance, has been selected to chair the OECD Committee on Fiscal (CFA) affairs, the OECD. . .

Europe

LuxLeaks whistleblowers Deltour and Halet convicted of theft by Luxembourg court, receive suspended sentence and fines, journalist acquitted: Luxemburger Wort→

June 30, 2016

See: Luxemburger Wort, More: The Guardian, Irish Times, Reuters.

No Picture
Europe

EU Parliament tax committee supports measures combating MNE tax avoidance

June 21, 2016

The European Parliament’s committee on tax rulings on June 21 voted in favor of a report calling for new measures to counter multinational . . . 

Cyprus

Cyprus to implement country-by-country reporting: Deloitte→

May 13, 2016

See: Deloitte

Europe

Authors analyze cross-border group financing behavior of MNEs in Germany: Stefan Greil and Dirk Schilling / SSRN →

April 22, 2016

See: SSRN.

Multinational

Millions of leaked documents from Panamanian law firm expose tax evasion and other crimes protected by offshore industry: ICIJ→

April 4, 2016

See: ICIJ.

Asia-Pacific

 S. Korea to help neighboring countries combat MNE tax avoidance, induce countries to join BEPS effort:  Yonhap→

March 30, 2016

See: Yonhap.

Posts navigation

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What’s Next

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RECENT COMMENTS
  • 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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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • 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

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021

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