Taiwan’s National Taxation Bureau of Taipei, Ministry of Finance (NTBT), in a notice dated December 28, reminded foreign business entities that they must pay the profit-seeking enterprise income tax according . . .
The BRIC countries of Brazil, Russia, India, and China have agreed to strengthen cooperation in areas such as transfer pricing and automatic exchange of financial account information to jointly crack . . .
China will complete its plan to replace the business tax with a value-added tax (VAT) for the services sector in 2016, the official state news agency Xinhua reported Monday. VAT reform will be implemented . . .
The US is considering changes to draft US Model Income Tax Convention provisions released last May, including several changes to provisions that deny tax treaty benefits to related party payments that are subject to a special tax regime (STR) . . .
The US IRS on December 21 released proposed regulations requiring annual country-by-country reporting . . .
Singapore’s Ministry of Finance on December 18 announced that tax treaties signed by Singapore and Ecuador . . .
The European Court of Justice on December 17 ruled in Timac Agro Deutschland v.Finanzamt Sankt Augustin (C‑388/14) as . . .
Japan and Germany on December 17 signed a tax treaty, wholly amending the . . .
A tax treaty between Hong Kong and the United Arab Emirates entered into force . . .
Source: ABC News (Australian Broadcasting Corporation), See also: Reuters, Wall Street Journal. For the report, see ATO. For explanatory material, see, ATO.
The Australian government on December 17 issued detailed guidance on newly enacted Subdivision 815-E of the Income Tax Assessment Act 1997 concerning transfer pricing documentation . . .
The US has posted new frequently asked questions (FAQs) to its FATCA website regarding registration for nonreporting financial institutions in Model 1 IGA jurisdictions and self-certifications on similarly agreed forms . . .
Tax officials from 11 developing nations described the most common practices MNEs use to shift profits out of their countries, obstacles that prevent their countries from stopping these practices, and their reactions to the OECD/G-20 base erosion profit shifting (BEPS) project, responding to a UN request for . . .
The Italian Parliament, on August 11, converted a series of tax incentives into law without modification, writes EY in an August 25 report. Included are increased notional interest deduction benefits, a tax credit for new plants and equipment, and an expanded withholding tax exemption for interest and substitute tax for loans. For discussion, see EY.
The US IRS, on August 7, has requested public comments on the information collection requirements related to compensatory stock options under section 482 transfer pricing regulations . . .
The European Commission has launched a call for applications for a newly established expert group on automatic exchange of financial account information for direct taxation purposes. The . . .
The European Union’s competition commission has requested information from Luxembourg to determine if tax deals granted to Amazon violate state aid rules, according to unnamed sources interviewed for a July 3 FT report.
Meanwhile, the EU is scrutinizing Luxembourg’s taxation of Microsoft’s and McDonald’s operations, according to a July 4 Bloomberg article.
The actions appear to be part of a wider investigation into whether tax rulings
Cameroon, on June 25, signed the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 65th signatory. To enter into force, the convention must be ratified by Cameroon. Release
Government representatives at a May 15 consultation defended draft OECD guidance on hybrid mismatch arrangements that uses a 10 percent ownership threshold to determine whether parties to a hybrid instrument are related.
The guidance, released March 19, responds to action item 2 of the OECD’s base erosion and profit shifting (BEPS) . . .
(Updated 12/10/2015) The European Council, during a December 8 meeting, formally agreed to an amended directive requiring EU States to exchange information automatically on advance cross-border tax rulings and . . .
Niue on November 27 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 92nd signatory. . .
Canada and the UK have signed an agreement specifying the procedures for arbitration of tax disputes between the two nations, Canada’s Department of Finance . . .
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
Switzerland’s Federal Council today announced that it has adopted a dispatch on a double taxation agreement signed with Oman on May 22. The agreement has been . . .
The OECD will lead a guidance project designed to help tax administrations determine the price of mineral commodities for transfer pricing purposes as a part of its effort to address the tax avoidance concerns of developing nations, a . . .
Japan and Germany have reached an agreement in principle on a new tax treaty, Japan’s Ministry of Finance announced July 16. The new treaty will include an arbitration clause . . .
The US Treasury Department has updated its FATCA website, reporting that the Philippines has signed a Model 1 intergovernmental agreement (IGA) with the United States as of July 13. . .
A bill introduced by Senate Finance Committee Member Ron Wyden (D-Ore) to amend US passive foreign investment company (PFIC) rules would clarify the active insurance exception but could also create problems for companies that underwrite catastrophic risks, writes PwC in a June 29 analysis of the bill. See, PwC.
The US Treasury Department has updated its FATCA website, reporting that Uzbekistan has signed a Model 1 intergovernmental agreement (IGA) with the United States as of April 3. The text of the agreement is available. See, Model 1 IGA.
The US Treasury Department has updated its FATCA website, reporting that Croatia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of March 20. The text of the agreement is available. See: Model 1 IGA
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