Pieter de Ridder has joined Mayer Brown’s tax, transactions, and consulting practice in Singapore as a partner, the firm announced February 16. De Ridder has over 20 years of experience advising multinational companies and institutions that operate in Asia, most recently as partner and head of Loyens & Loeff’s Singapore office. Prior to arriving Singapore in 1996, he was based in Jakarta . . .
In comment letters released February 11, business representatives argued that the OECD should not adopt a proposal to limit MNE interest deductions using a group-wide test, as proposed in a discussion draft released under OECD base erosion and profit shifting (BEPS) plan. Just over 100 comment letters were released in response to the discussion draft, issued December 18 . . .
Italy’s parliament, on December 22, passed a law introducing a patent box regime and adding a new research and development (R&D) tax credit, among other measures, writes EY in January 2 tax alert. For discussion, see EY.
EU finance ministers on December 9 adopted a directive to extend mandatory automatic exchange of information between tax administrations to interest, dividends, and other income, and to account balances and sales proceeds from financial . . .
The US Public Company Accounting Oversight Board is investigating whether PwC’s provision of both tax advice and auditing services to Caterpillar Inc. created a conflict of interest, and whether US rules should be modified to prohibit accounting firms from operating in these dual roles, according to a November 19 article by Michael Rapoport of the Wall Street Journal. For in-depth discussion, see Wall Street Journal.
European Court of Justice Advocate General Juliane Kokott in an October 23 opinion advised the ECJ to abandon the Marks & Spencer exception for loss relief for foreign group members and sanction UK legislation that restricts such loss relief.
Kokott said the . . .
The Rascon CPA Firm has provided a report of October 3 comments made by Robert Stack, Treasury deputy assistant secretary (International Tax Affairs) concerning the OECD’s base erosion . . .
China’s central government on Sept. 25 announced it will offer tax breaks to encourage enterprises to upgrade equipment and increase research and development (R&D) in an effort to improve the manufacturing . . .
Singapore’s Ministry of Finance announced, on August 27, that it will modify portions of the draft Goods and Services Tax (Amendment) Bill 2014 and related subsidiary legislation in response to suggestions lodged pursuant to a public consultation. Press release, Annex (summary of GST consultation and responses)
The governments of Luxembourg and Estonia, on July 7, signed an agreement for the avoidance of double taxation. Text (PDF 1.05MB)
Kirkland & Ellis LLP, on July 16, announced that Dean S. Shulman has joined the Firm’s New York office as a partner in the Tax Practice Group. Release
In a July 2 report, Deloitte analyzes significant corporate tax proposals in a tax reform package released by the Spanish government on June 20. The corporate tax reforms include a reduction in corporate tax rates for 2015 and 2016; new anti-hybrid rules; changes to controlled foreign company rules; loss of deductions for intragroup profit participating loan interest; modifications to net operating loss carryforward rules, and changes to transfer pricing definitions, documentation, and valuation method hierarchies, writes Deloitte. For more details, see Deloitte.
India’s tax income tax department is considering requiring taxpayers to report indirect transfers abroad of assets located in India and may extend the reporting requirement to prior tax years, writes Gireesh Chandra Prasad of the Financial Express, quoting an unnamed tax official. For more details, see Financial Express.
The IRS has released Rev. Proc. 2014-39, which includes an updated qualified intermediary (QI) agreement. The revenue procedure supersedes the QI agreement originally released as Rev. Proc. 2000-12. Rev Proc. 2014-39 also outlines the application procedures and the requirements for qualified intermediary status under Chapters 3, 4, and 61 and Section 3406. Rev. Proc. 2014-39
The US IRS, on June 24, released Rev. Proc. 2014-38, which includes a revised foreign financial institutions (FFI) agreement for FFIs that wish to enter into an agreement with the IRS to be treated as a participating FFI under the Foreign Account Tax Compliance Act (FATCA)
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Azerbaijan and Saudi Arabia, on May 13, signed an agreement for the avoidance of double taxation and an agreement to prevent tax evasion, the Azerbaijani Foreign Ministry announced on its website. Press Release.
The Australian Taxation Office announced December 7 that it will fulfill its obligation to publicly report tax information of corporate entities pursuant to new tax transparency . . .
Malta and Curaçao signed a tax treaty on November 18, Malta’s Ministry for Finance . . .
Singapore’s Ministry of Finance (MOF) published on November 17 a summary of its responses to a public consultation on the Draft Income Tax (Amendment) Bill 2016, indicating which commentator suggestions have been accepted and rejected. See: Summary of Responses.
The US Treasury Department has updated its FATCA website, reporting that San Marino and the US signed a Model 2 intergovernmental . . .
Decisions on the advance pricing agreements may be released as soon as next Wednesday, writes Tom Fairless of The Wall Street Journal. See: The Wall Street Journal. More: Bloomberg. Related: MNE Tax.
The EU Commission on October 8 launched a public consultation on an EU-wide common consolidated corporate tax base (CCCTB). Through the . . .
The OECD has published entries in its online library for the 13 final reports to be delivered under the OECD/G20 base erosion profit shifting (BEPS) plan, adding summaries of 11 reports that reveal some of the content of the coming . . .
Canada resolved 115 Mutual Agreement Procedure (MAP) program cases through negotiations with other countries during FY 2014/2015, slightly more than the annual tally of settled negotiable MAP cases in preceding periods . . .
The Indian government has announced that it has settled 35 transfer pricing disputes with the US in the information technology services and information technology enabled services industries thanks to a framework agreement signed . . .
El Salvador on June 1 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has announced. The country is the 86th signatory to the agreement, which is designed combat offshore tax evasion through international cooperation. See, release.
Switzerland’s Federal Department of Finance on May 21 announced that Switzerland and Grenada have signed a tax information exchange agreement (TIEA). The agreement, signed . . .
Hong Kong on May 15 announced that orders were gazetted to implement tax treaties signed with South Africa and the United Arab Emirates and notes exchanged with Japan regarding interpretation of the 2010 Japan/Hong Kong treaty. The tax treaty with South Africa, signed October 2014, reduce. . .
India’s Lok Sabha on March 30 passed through a voice vote Finance Bill 2015, which contains the government’s tax proposals. The bill was passed after Finance Minister Arun Jaitley offered several amendments, including one that provides that foreign firms will be exempt . . .
The US IRS, in a technical advice memorandum released April 24, ruled that a refund claim filed in year 13 is not timely for taxes paid for year 2 if the claim for refund results from a net operating loss (NOL) in year 4 that was generated when the taxpayer made a timely election to deduct foreign taxes paid in lieu of the previously claimed . . .
The Netherlands and Malawi have signed a revised tax treaty that includes antiabuse provisions preventing the benefits of the treaty from being used solely to avoid tax, The Netherlands government said on April 23. Dutch Minister for Foreign Trade and Development Cooperation Lilianne Ploumen said that the antiabuse provisions, which relate to taxes on dividends, interest and royalties . . .
The State of California Franchise Tax Board (FTB) has concluded that some payments received pursuant to a cost sharing arrangement (CSA) constitute gross receipts for purposes of the California sales factor. In TAM 2015-1, dated . . .
Switzerland and the European Union on March 19 initialed an agreement to commence automatic exchange of information from 2018 once the necessary legal basis has been created, Switzerland’s Federal Department of Finance has . . .
Switzerland and Australia have signed a joint declaration expressing their intent to begin automatically exchanging information on tax matters using internationally agreed standards beginning in 2018, the Swiss government announced March 3. Collection of the data will begin in 2017. The agreement, signed in Canberra, is the first declaration on automatic exchange of information. . .
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