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OECD consults on tax treaty benefits for non-CIV funds under BEPS rules
The OECD has requested taxpayer input on how to apply rules on entitlement to tax treaty benefits to non-CIV funds, which are investment vehicles . . .
Kenya signs agreement to fight offshore tax evasion and avoidance
Kenya on February 8 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters . . .
Improving the OECD transfer pricing guidance on intragroup services
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the OECD should improve the transfer pricing guidelines on intragroup services by reducing the number of group companies allocated low value centralised services, removing the benefits test, and providing guidance on high value services. . . .
The new Dutch transfer pricing guidance, what has changed?
Jian-Cheng Ku and Robin Theuns of DLA Piper, Amsterdam, analyze Netherlands transfer pricing guidance released April 22 ws.hich outlines the State Secretary of Finance’s interpretation of the arm’s length principle and reflects the Ministry’s views on amendments made to the OECD transfer pricing guidelines as a result of the BEPS project.. . . .
17 nations placed on EU blacklist of tax havens
Davide Anghileri of the University of Lausanne discusses the EU’s tax blacklist, released December 5, which identifies 17 “non-cooperative jurisdictions” and warns many others that they could be listed in the future if they do follow through with commitments to improve specified aspects of their tax regimes . . .
US court determines IRS properly denied discretionary tax treaty benefits
Amanda Varma and Brigid Kelly of Steptoe & Johnson, Washington, discuss the implications of the US district court’s decision Starr International Co. Inc. v. US, issued August 14, where the court concluded that the US competent authority acted reasonably when it denied a taxpayer’s request for discretionary tax treaty benefits under the US-Switzerland tax treaty. . .