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Europe
EU proposal requires disclosure to tax authorities of cross-border tax planning schemes by intermediaries, clients
Tax advisors, accountants, banks, lawyers, and other intermediaries who design and promote potentially aggressive cross-border tax planning schemes and, in some cases, the clients that receive such advice, would be required to meet new reporting. . .
Americas
Tax officials crafting plan to jointly identify large multinationals with low risk of tax avoidance
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Asia-Pacific
EU, China sign customs cooperation agreement
The European Union and China on June 2 signed a customs cooperation agreement covering the years 2018–2020, providing the priorities for EU-China customs cooperation, writes Davide Anghileri . . .
Americas
Americas
Tax rules for US partners of foreign partnerships that hold CFC stock need clarity
Monte A. Jackel, Senior Council at Akin, Gump, Strauss, Hauer & Feld, writes about the need for US tax guidance addressing situations where the stock of a controlled foreign corporation (CFC) is held by a foreign partnership whose partners consist of US persons . . .
Americas
G20
Americas
Japan, Bahamas agree to automatic exchange of financial information for tax purposes
Japan and the Bahamas on February 9 signed a protocol to their tax information exchange agreement (TIEA), agreeing to upgrade the agreement by providing for automatic exchange . . .
Americas
Europe
Americas
Sen. Bill Cassidy joins US Senate Committee on Finance
Senator Bill Cassidy (R-La.) will serve on the US Senate Finance Committee in the 115th Congress, replacing retiring Sen. Dan Coats of Indiana. His assignment was announced Tuesday by Finance . . .
Council of the European Union
EU Court of Justice rules in Banco Santader case involving Spanish tax system, State aid: Curia→
See: Curia. This ruling will be covered in detail in a future MNE Tax article.
Americas
Europe
Draft UK tax guidance clarifies hybrid mismatch law
The UK, on December 9, published draft tax guidance to clarify aspects of hybrid mismatch legislation which will take effect January 1, 2017. The legislation, introduced . . .
Americas
Europe
Switzerland announces entry into force of tax treaties with Liechtenstein, Oman
Davide Anghileri of the University of Lausanne discusses Switzerland’s new tax treaties with Liechtenstein and Oman . . .
Featured News
Vietnam publishes draft transfer pricing law to combat tax avoidance
Chau Huy Quang and Cao Dang Duy of Rajah & Tann LCT Lawyers, Hanoi, discuss a new Vietnam draft law which would establish uniform transfer pricing rules, including an expansive definition of “related party transactions,” and impose new conditions on the deductibility of common expenses arising between related parties, such as interest and service fees . . .
European Commission
Ireland appeals Apple state aid decision
The Irish government today filed suit to annul the EU Commission’s decision in the Apple case, which concluded that Ireland granted Apple about €13 billion (USD 14.5 billion) in illegal state aid by . . .
Americas
Facebook battling IRS in Tax Court over royalty income from related Irish company
Facebook has filed a petition in US Tax Court, contesting IRS adjustments that increased the social media giant’s royalty income by about $85 million in 2010 on account . . .
Europe
Switzerland weighs withholding tax change to ease multinational group financing
The Swiss government has proposed to amend Switzerland’s withholding tax regime to facilitate the raising of capital by multinational groups, writes Davide Anghileri, PhD researcher and lecturer at the University of Lausanne in Switzerland . . .
Multinational
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Featured News
OECD releases discussion draft on group ratio rule for tax deductiblity of MNE interest payments
The OECD on July 11 released a discussion draft requesting stakeholder feedback on issues associated with drafting model tax guidance on a group ratio rule for use by countries that wish to address multinational corporation tax . . .
Asia-Pacific
New Zealand to enhance tax laws to combat MNE tax avoidance
New Zealand intends to introduce hybrid mismatch rules and will consult on new rules to prevent multinational corporations from stripping profits out of the country through excessive. . .
Asia-Pacific
Singapore joins BEPS project to fight multinational corporation tax avoidance
Singapore today announced that it will participate in the OECD/G20 base erosion profit shifting (BEPS) plan, adopting BEPS minimum standards, including country-by country. . .
Council of the EU
Czech Republic threatens to derail EU anti-tax avoidance deal unless VAT fraud addressed
Ahead of tomorrow’s ECOFIN meeting seeking agreement the EU anti-tax avoidance directive, Czech Republic finance Minister Andrej Babiš is warning that, to win his country’s support for the directive, EU ministers . . .
Europe
EU Commission publishes State aid decision on Fiat’s Luxembourg tax ruling
The EU Commission today published the non-confidential version of its decision concluding that an advance pricing agreement (APA) granted to a Fiat subsidiary by Luxembourg is illegal . . .
Asia-Pacific
India issues draft tax rules on indirect transfers, seeks feedback on GAAR
India’s Central Board of Direct Taxes (CBDT) has issued draft tax regulations on the indirect transfer abroad of Indian assets and has requested stakeholder feedback on guidance to implement India’s general antiavoidance . . .
Africa
Americas
Americas
Europe
Liechtenstein studying implementation of BEPS tax measures
Liechtenstein’s government on March 4 announced that it has instructed its tax authority to prepare a consultation report on implementing tax measures in the . . .
Americas
US Democrats offer bill to curb tax inversions by limiting earnings stripping
Two ranking US Democrats today introduced a tax bill designed to lessen the attractiveness of corporate inversions by limiting companies’ ability . . .
Americas
US confirms plan to begin bilateral APA negotiations with India
The US IRS today confirmed that, beginning February 16, the US competent authority will accept applications for Indian advance pricing agreements (APAs), citing. . .
Americas
Japan and Chile sign first tax treaty
Japan and Chile signed a tax treaty on January 22, the first such agreement between the nations, Japan’s . . .
Asia-Pacific
Cyprus-Georgia tax treaty enters into force
A tax treaty between Cyprus and Georgia entered into force on January 4, Cyprus’s Ministry of Finance . . .
Americas
