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OECD updates tax guidance on common reporting standard, CRS XML schema
The OECD has issued new tax guidance on the common reporting standard, including the CRS XML schema, writes Davide Anghileri of the University of Lausanne . . .



EU Council reaches ATAD II compromise to close hybrid mismatch tax loophole
Davide Anghileri, of the University of Lausanne, discusses an EU Council compromise agreement, reached today, on a directive addressing hybrid mismatches involving non-EU countries . . .

Australia consults on establishment of beneficial ownership registry
The Australian government is moving forward with efforts to establish a public register of the beneficial owners of companies to put an end . . .

Mexico: transfer pricing adjustment rules adopted
Yoshio Uehara and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cía., Mexico City, discuss new Mexican provisions allowing for transfer pricing adjustments as of January 1 . . .


Szubin to serve as US Treasury acting secretary
Adam Szubin will serve as Acting Secretary of the US Treasury effective immediately, Treasury announced in a . . .

Cyprus specifies notification requirement for country-by-country reporting
Cyprus’ Ministry of Finance on December 22 announced that it will issue a decree setting out the requirements for country-by-country reporting . . .

India-Cyprus tax treaty enters into effect
The revised India-Cyprus tax treaty, signed November 18, has entered . . .

US, St. Lucia FATCA IGA enters into force
The US Treasury Department has today updated its FATCA website, reporting that a Model 1 FATCA intergovernmental . . .


No harm to EU investment under corporate debt-bias tax reform, Commission paper concludes
Davide Anghileri of the University of Lausanne discusses an October 27 EU Commission working paper on debt bias tax systems of the EU member states which concludes that reform can be revenue neutral and maintain EU investment . . .

Economic analysis predicts EU would benefit from CCTB, CCCTB
An EU Commission paper released October 27 uses economic modelling to conclude that recent EU proposals for a common corporate tax base (CCTB) and a common consolidated corporate tax base with formula apportionment (CCCTB) would result a fairer and more efficient tax system, writes Davide Anghileri, of the University of Lausanne, Switzerland . . .

OECD releases 17 comments on draft addressing MNE tax avoidance though branch mismatches
The OECD has released 17 comment letters responding to a draft report that explores how countries can improve their tax laws to counteract tax avoidance by multinational enterprises (MNEs) through . . .

UK details businesses’ use of patent box tax incentive
The UK gave away £342.9 2 million (USD 452.6 million) in tax breaks, mostly to large corporations, through its patent box tax incentive the first year the program was established, data released today by HM Revenue and Customs has . . .


Treasury’s plan to fix to US debt-equity tax regs falls short, GOP lawmakers say
US Treasury’s plan to revise six problematic areas in the proposed section 385 debt-equity regulations does not go far enough to allay concerns about regs’ negative impact on the US economy, Republican lawmakers . . .

Canada’s new international business tax proposals: a closer look
Goodmans LLP tax attorney, Kabir Jamal, provides an analysis of the international tax proposals in the Canadian government’s draft tax bill, issued July 29, including measures that address foreign exchange gains on foreign-currency debt, back-to-back loan and royalty arrangements, and country-by-country reporting . . . .


Promoting tax certainty on the agenda of the next G20 presidency
The issue of tax certainty will be addressed by the G20 when Germany takes up its presidency in 2017, said Martin Kreienbaum, Director General, International Taxation, at Germany’s Federal Ministry of Finance at the 2016 OECD International Tax Conference . . .

EU State aid probe into tax rulings extends to group financing companies, TNMM use
The EU Commission on June 3 released a working paper identifying several categories of Member State transfer pricing rulings that raise potential State aid concerns because they sanction profit allocations. . .

Romania joins countries leading BEPS plan implementation to fight MNE tax avoidance
The Romanian government, on June 2, announced that it will join countries working on the next phase of the OECD/G20 base erosion and profit shifting (BEPS) project as an associate, developing standards and monitoring the implementation of the BEPS . . .




Ireland updates FATCA guidance
Irish Tax and Customs on March 21 released Frequently Asked Questions (FAQs) on FATCA . . .



South African budget takes aim at hybrid debt instruments, share buybacks
South Africa’s 2016 budget includes a measure to curb perceived abuses associated with hybrid debt instruments and a warning about future action on share buybacks, writes South African tax practitioner, Peter Dachs . . .

EU state aid decisions on Starbucks and Fiat tax rulings challenged in court
As expected, the EU Commission will need to defend in court its contention that advance pricing agreements (APAs) granted to a Starbucks subsidiary by the Netherlands and to a Fiat subsidiary by Luxembourg . . .

