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Indian secondary adjustments for transfer pricing: what you need to know about the new rules
India transfer pricing and tax litigator Ajit Jain discusses new transfer pricing rules providing for secondary adjustments . . .
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Austria
Estonia
Americas
Featured News
OECD releases 33 comments to draft guidance on tax treaty access by non-CIV funds
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Asia-Pacific
Australian diverted profits tax legislation introduced
Julian Feiner of Dentons, London, discusses proposed Australian legislation, introduced into Parliament February 9, that would implement a diverted profits tax, comparing the draft to the UK DPT . . .
Europe
Apple appeals State aid decision in EU court
Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, Galway, provides an update of the EU Commission’s State aid challenge to tax rulings granted by Ireland to Apple . . .
International Monetary Fund
Asia-Pacific
Indian circular clarifies coming GAAR: Central Board of Direct Taxes→
See: Central Board of Direct Taxes. *The circular will be analyzed in a forthcoming MNE Tax article.
Africa
US, Algeria FATCA agreement enters into force
The US Treasury Department has updated its FATCA website, reporting that a FATCA IGA signed by the US and Algeria entered . . .
Americas
Greece, US sign FATCA agreement
The US Treasury Department updated its FATCA website January 24, reporting that Greece has signed a Model 1 intergovernmental agreement (IGA) and an understanding . . .
Americas
New US House Ways and Means Committee members selected
US Reps. David Schweikert (R-AZ), Jackie Walorski (R-IN), Carlos Curbelo (R-FL), Brian Higgins (D-NY) . . .
Americas
US final, temporary tax regs on foreign currency gains and losses released
The US Treasury Department, on December 7, issued final, temporary, and proposed regulations relating to the taxation of foreign currency gains . . .
Americas
Chile, Switzerland agree to automatic exchange of information
Joint declarations were signed by Chilean and Swiss officials December 6 to introduce automatic exchange of information in tax matters between the countries, writes Davide Anghileri of the University of Lausanne . . .
Asia-Pacific
Protocol to Singapore-Russia tax treaty enters into force
A protocol amending the 2002 Singapore-Russia tax treaty entered into force on November 25, the Inland Revenue Authority of Singapore has . . .
Asia-Pacific
Asia-Pacific
Africa
Americas
Africa
Ireland says tax treaty with Ethiopia entered into force, updates status of treaties with Ghana, Oman, South Africa
Irish Revenue has announced that a new double taxation agreement with Ethiopia entered into force on August 12. The treaty, signed November 3, 2014, will . . .
Americas
Americas
Americas
Europe
Africa
India-Mauritius tax treaty re-negotiated: what it means for international business
Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Shipra Padhi, a senior international tax specialist based in the firm’s Mumbai office, discuss how the taxation of foreign investment in India will change as a result of the renegotiation of the India-Mauritius tax treaty . . . .
Europe
Asia-Pacific
New Zealand details new law extending goods and services tax to cross-border services
New Zealand’s Inland Revenue Department on May 17 published a special report providing information on a new law that will impose the goods and services tax (GST). . .
Asia-Pacific
Japan and Belgium agree to terms of new tax treaty
Japan and Belgium have agreed to the terms of new tax treaty, Japan’s Ministry of Finance announced . . .
Europe
Multinational
FATCA/CRS
Americas
Featured News
Tax proposals in Indian budget affect international business, experts say
India’s Budget 2016–17, offered today by Finance Minister Arun Jaitley, includes a number of tax measures of interest to international business, according to tax specialists . . .
Europe
EU finance ministers wary of anti-tax avoidance proposal
EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for . . .
Europe
EU Commission staff analyzes financial transaction tax→
The paper, Financial Transaction Taxes in the European Union, was written by Thomas Hemmelgarn, Gaëtan Nicodème, Bogdan Tasnadi, and Pol Vermote. See: EU Commission.
Americas
MNEs with US activity vulnerable to US taxes on profits shifted to non-US group members using ECI theory, CPAs warn: Journal of Accountancy→
See: Profit Shifting: Effectively Connected Income and Financial Statement Risks, by Thomas J. Kelley, David L. Koontz, Jeffery M. Kadet. Available at: Journal of Accountancy.
Multinational
Americas
US and India to begin negotiating bilateral APAs, 100 transfer pricing disputes resolved
Reassured by the successful settlement of numerous long-pending transfer pricing disputes, the US competent authority has agreed to soon begin negotiating bilateral advance . . .
Update (2/1/2016): US confirms it will accept Indian bilateral APA applications: The US IRS, on February 1, confirmed that, beginning February 16, the US competent authority will accept applications . . .
Europe
