India’s Central Board of Direct Taxes (CBDT) has announced that India has resolved 180 double taxation disputes since April 1, 2014. The cases, worth a combined Rs 5000 crore (USD 730 million), were settled . . .
BMR & Associates has announced that Bhavik Timbadia has joined the firm’s transfer pricing team as a partner. Timbadia will work out of the firm’s . . .
The Luxembourg Ministry of Finance today announced that Luxembourg and Senegal have signed a new tax treaty. The double tax avoidance agreement was signed by Pierre Gramegna, Luxembourg’s . . .
Google’s recently announced settlement with UK HM Revenue and Customs requires the company to pay additional tax on account of transfer pricing adjustments and does not include any diverted profits tax (DPT) payment, HMRC documents . . .
Also, UK tax officials and Google reps have been summoned to appear at a Public Accounts Committee hearing February 11 to testify about the settlement. See: The Guardian.
Professor Edoardo Traversa, Matthieu Possoz, and Elien Van Malder analyze the EU Commission’s proposed anti-tax avoidance directive, released today, noting that the document confirms that prevention of avoidance and abuse, rather than removal of cross-border obstacles, has become the dominant objective of EU tax policy.
The Ministry of Finance of Japan has announced Japan and Slovenia will begin their first round of negotiations . . .
Taiwan and Canada have signed an arrangement to avoid double taxation, Canada’s Department of Finance announced today. The . . .
The US IRS on January 11 released Notice 2016-10, describing regulations Treasury intends to release relating to the treatment under sections 853 and 905(c) of foreign tax refunds . . .
Four influential US Senators have urged the Obama administration to examine whether it should use its regulatory authority to impose additional taxes on EU citizens and corporations in retaliation for EU State aid . . .
The UK’s HM Revenue & Customs on January 14 advised that it is seeking feedback from business on how to respond to European Court of Justice decisions in Larentia + Minerva and Marenave and Skandia . . .
The UK-Sweden tax treaty, signed March 26, 2015, entered into force on December 20, 2015, HM Revenue and Customs announced January 13. The treaty . . .
The fourth protocol to the China/Hong Kong income tax arrangement, signed April 1, 2015, entered into force on December 29, 2015, the Hong Kong Inland Revenue Department . . .
The European Commission will present a new package of tax proposals by the end of January to combat tax avoidance by multinationals and tax fraud, EU commissioner Pierre Moscovici told . . .
Ireland’s tax treaty with Zambia and protocols to tax treaties with Germany and Luxembourg have entered into force and effect, Irish Tax and Customs. . .
Lin Homer announced Monday that she will leave HM Revenue and Customs (HMRC) in April, after more than four years as Chief Executive and Permanent . . .
The EU Commission on Monday announced that it has concluded that Belgium’s excess profits tax regime is illegal under EU State aid . . .
The UK’s HM Revenue & Customs on January 8 announced that tax treaties with Croatia, Bulgaria, and Kosovo have entered into force. The UK’s tax treaty with Croatia entered into . . .
Jukka Karjalainen has joined Baker & McKenzie’s UK business transformation practice as a tax leader, the firm announced January 5. Karjalainen, a transfer pricing specialist, will be advising . . .
The New Corporate Migration: Tax Diversion Through Inversion, by Cathy Hwang. See: SSRN.
See: Tax Legislation and the Notion of Fiscal Aid – A Review of Five Years of European Jurisprudence by Wolfgang Schön. (December 22, 2015). Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2015-14. Available at SSRN.
Steptoe & Johnson, on January 4, announced that tax attorney Amanda Varma has been been promoted to . . .
Singapore’s Inland Revenue Authority (IRAS) on January 4 published the third edition of its transfer pricing guidelines, adding new information on the cost plus method and changing the guidance to reflect Singapore’s . . .
The Netherlands Ministry of Finance has issued guidance on new transfer pricing documentation standards . . .
The government of Luxembourg has announced that protocols signed with Ireland, Mauritius, Lithuania and United Arab Emirates entered into force on December 11 and . . .
The US IRS has released its annual “no rule” list, adding foreign base company income issues to the list of topics that the agency will “not ordinarily” address in private letter rulings . . .
The Indian government, in a notice dated December 21, announced that a tax treaty signed by India and the Republic of Macedonia . . .
Greenland signed the Multilateral Competent Authority Agreement, on December 17, becoming the . . .
The UK’s HM Revenue and Customs, on December 22, issued a series of draft examples illustrating the application of hybrid mismatch rules in previously released tax . . .
The Inland Revenue Authority of Singapore has announced that the Luxembourg-Singapore tax treaty, signed . . .
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