Americas
US IRS updates FATCA IDES user guide, releases ICMM report notifications guides
The US IRS, on March 5, announced it has updated the FATCA international data exchange service (IDES) user guide to add user . . .
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Americas
Edgar Klee joins Haynes and Boone’s Mexico City office
Tax lawyer Edgar Klee has joined Haynes and Boone’s Mexico City office as a partner, the firm announced March 2. Klee who is formerly with Turanzas, Bravo & Ambrosi, focuses on international corporate taxation. . .
Europe
European Parliament committee to investigate tax ruling practices of EU states
The European Parliament voted February 12 to establish a special committee to investigate the tax ruling practices of EU member states. The 45-member committee . . .
Americas
Carbone joins Willkie Farr & Gallagher in New York
Anthony J. Carbone has joined Willkie Farr & Gallagher’s New York office as a partner, the firm announced January 20. Formerly co-leader of Bingham McCutchen’s tax group, Carbone focuses on US and international tax planning strategies and the tax consequences of business and investment transactions. See, release.
Multinational
OECD releases 50 comments to BEPS discussion draft on dispute resolution mechanisms
The OECD on January 19 released comments to a discussion draft under action 14 of the base erosion profit shifting (BEPS) plan dealing with making cross-border tax dispute resolution mechanisms more . . .
Europe
Switzerland consults on legislation to implement automatic exchange of tax information
Switzerland’s Federal Council on January 14 launched two consultations on legislation that would enable automatic exchange of tax information with other nations. One consultation concerns approval and implementation of the OECD/Council of Europe Convention . . .
Asia-Pacific
Taiwan’s tax authority advises on new law that limits tax credits for dividend payments
The National Taxation Bureau of Taipei, Ministry of Finance (NTBT) on December 31 issued English-language guidance on a new law which reduces by half the tax credits available when dividends are paid to foreign or domestic taxpayers. The new law, passed by the
. . .
Europe
UK diverted profits tax hits MNEs that avoid PE rules, route profits through tax havens
The UK government on December 10 proposed a new 25 percent tax on “diverted profits,” targeting MNEs that engage tax avoidance transactions, including MNEs that “exploit” permanent establishment (PE) rules and that reduce their tax liability through transactions that lack substance. The new tax, first announced in UK Autumn Statement 2014, affects only large MNEs, is . . .
Americas
US IRS gives countries with “in substance” FATCA IGAs more time to sign IGAs, adds more countries to the “in substance” list
The US IRS on December 1 released an advance copy of guidance that provides that countries that have reached FATCA intergovernmental agreements (IGAs) “in substance” that do not sign an IGA by December 31 will continue to be treated as if an IGA was in effect as long as the country displays a “firm resolve” to sign an IGA as soon as possible. The new guidance . . .
Europe
Switzerland signs agreement for automatic exchange of information
Switzerland on November 19 signed a multilateral competent authority agreement, moving the country one step closer to adopting automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2018 . . .
Asia-Pacific
Revised treaty between Australia and Switzerland enters into force
A revised tax treaty and protocol between Australia and Switzerland, signed July 30, 2013, entered into force on October 14 , Australia’s tax authority has announced. Australian legislation enforcing the revised tax treaty received royal assent on September 24. See, release, Australia-Switzerland Tax Treaty (142 KB).
Europe
European Commission releases 2014 report on EU tax reform
The European Commission on October 13 released a report “Tax Reforms in EU Member States: 2014.” See, report (7.34 MB), summary.
Americas
Canadian Finance Minister tables tax measures
Finance Minister Joe Oliver on October 10 tabled in the House of Commons tax proposals to implement the government’s budget and about a dozen tax proposals not included in the budget.
International tax . . .
Americas
Isle of Man
Isle of Man signs TIEA with Swaziland
The Isle of Man has announced that it signed a tax information exchange agreement (TIEA) with the Kingdom of Swaziland on May 16.
The TIEA was signed by Eddie Teare MHK, the Isle of Man’s Treasury Minister, in the Isle of Man, and by Senator Martin G. Dlamini, Swaziland’s Minister for Finance, in Swaziland.
The Isle of Man has signed 42 tax agreements, including 32 TIEAs.
Multinational
Recoules appointed Taxand global head of indirect tax
Alain Recoules, of Taxand France been appointed global head of indirect tax, the firm has announced. Release
Featured News
OECD approves revisions to the Model Tax Convention
The OECD Council, on July 15, approved a 2014 update to the OECD Model Tax Convention. The update modifies Article 26 on exchange of information to allow for group requests. Changes are also made to the meaning of “beneficial owner” for purposes of the OECD Model Convention; to tax treaty issues related to emissions permits and credits; to the tax treaty treatment of termination of employment payments; and to Article 17 (Artistes and Sportsmen). No updates relate to the OECD’s BEPS project.
An updated Model Tax Convention will be published in next few months. See, 2014 Update to the Model Tax Convention, Release.
Americas
Asia-Pacific
Hong Kong enacts tax concessions for 2013-14
Hong Kong’s Legislative Council, on June 25, passed concessionary tax measures that reduce by 75 percent the profits tax, salaries tax, tax under personal assessment for tax year 2013-14, subject to a ceiling of $10,000 per case
Featured News
Asia-Pacific
Europe
France’s National Assembly passes amendment requiring public country-by-country reporting: Eurodad→
The amendment will be taken up by the Senate this week. See: Eurodad.
Europe
Europe
The State Administration of International Tax Avoidance: Omari Y. Marian / SSRN →
Professor Omari Y. Marian of the University of California, Irvine School of Law analyzes the “Lux Leaks” tax rulings, concluding that the Luxembourg tax authority, in exchange for payment, purposefully created legal differences between the tax laws of source and residence jurisdictions for multinationals to exploit. See: SSRN.
Asia-Pacific
Philippines-Qatar tax treaty enters into force
The Philippines-Qatar double taxation agreement, signed December 2008, has entered into force as. . .
Asia-Pacific
Hong Kong, South Africa tax treaty enters into force
A new tax treaty between Hong Kong and South Africa entered into force on October 20, Hong Kong’s Inland Revenue Department . . .
Americas
US signs first competent authority arrangements to implement FATCA IGAs with Australia and UK
The US IRS announced November 24 that it has signed competent authority arrangements (CCAs) with Australia and the UK to establish . . .
Europe
Asia-Pacific
Asia-Pacific
Hong Kong, Italy tax treaty enters into force
A tax treaty between Hong Kong and Italy signed January 2013 has entered into force as of August 10, Hong Kong’s Inland Revenue Department has . . .
Asia-Pacific
Australian Senate report advocates heightened public disclosure of multinationals’ tax affairs
An interim report prepared by the Australian Senate Economic References Committee, released August 18, calls for laws mandating greater public disclosure of tax information of large . . .
More News
OECD releases report assessing the practices of 56 tax administrations
The 384-page OECD report, released August 11, compares tax administrations on their performance and discusses best practices and trends. See: OECD
Asia-Pacific
Australian draft laws introduce country-by-country reporting, double penalties for profit shifting and tax avoidance
Australia’s Treasury on July 6 released draft laws introducing country-by-country reporting documentation standards and doubling administrative penalties for multinational entities that have entered into tax avoidance or profit shifting schemes. Both measures were first announced . . .
Europe
Airbus and tax justice campaigner questioned by European Parliament committee
The EU needs to be mindful of tax competition from countries outside the EU and adopt policies that will allow EU companies to remain competitive, Airbus’s head of tax, Guillaume de La Villeguérin, told the European Parliament’s Special Committee . . .
Europe
Iceland amends transfer pricing rules
Iceland has revised its transfer pricing rules to no longer require documentation for domestic transactions, narrow the definition of related entities, and remove a reference to the . . .
Americas
US IRS’s Heather Maloy to join EY
EY has announced that Heather Maloy, the IRS Commissioner for the Large Business & International (LB&I) Division, will join the firm’s national tax department as tax controversy . . .
Americas
Brazil modifies calculation of commodities transfer prices
The Brazilian Federal Revenue Department on June 8 issued Normative Instruction 1568/15 modifying the calculation of transfer prices based on Brazilian commodities methods applicable to imports and exports, writes PwC in a tax alert. See, PwC.
Featured News
OECD releases model legislation, competent authority agreements to implement country-by-country reporting
The OECD on June 8 released model domestic legislation and competent authority agreements to implement the transfer pricing country-by-country (CbC) reporting plan developed under the OECD/G20 base erosion profit shifting (BEPS) project. The work furthers action 13 of the OECD/G20 BEPS plan and . . .
Americas
BMC Software wins US dividend repatriation case on appeal
The US Court of Appeals for the Fifth Circuit has ruled, in BMC Software Inc., decided March 13, that accounts receivables created under a transfer pricing closing agreement are not a related-party loans causing partial disallowance of the . . .
