The OECD has released a guide for its Tax Inspectors Without Borders (TIWB) initiative, a program which recruits currently serving or recently retired tax officials to work alongside tax officials in developing nations on international tax audits and audit-related . . .
A proposal to establish a committee of inquiry in European Parliament to investigate the private tax ruling practices of member states gained the required support of 25 percent of lawmakers on January 14, moving the measure one step closer to being voted on by the full parliament. The question of whether to set up the committee . . .
The Inland Revenue Authority of Singapore (IRAS) on January 6 released updated transfer pricing guidance in an e-Tax Guide, consolidating four previous e-Tax Guides into the document. The 102 page document discusses the application . . .
Luxembourg’s Parliament on December 18 passed a law which sets out the procedures required to obtain a private tax ruling, thereby formalizing existing administrative practice, and which describes the application of the arm’s length principle in transfer pricing, writes EY in a December 19 tax alert. For discussion of the new legislation, see EY
The South African Government, on December 17, released on its website a draft guide for financial institutions. The guide deals with issues arising from an intergovernmental agreement signed by South Africa and United States under FATCA. See, Guide.
Switzerland’s Federal Department of Finance on November 14 announced that the ratification procedures for new double tax treaties with Australia, Hungary, and China have been concluded and all three treaties have entered into force. The new treaties with Australia and Hungary entered into force . . .
The UK and Germany have agreed to a joint proposal on harmful tax practices which limits the patent box tax break, writes Reuters, quoting unnamed German government officials. The countries will present the proposal to the OECD Forum on Harmful Tax Practices. For details, see Reuters.
Michael Durst has joined the UN Committee of Experts Subcommittee on Natural Resources Taxation, reports the International Centre for Tax and Development (ICTD) in an October 10 release.
Durst is an ICTD researcher and writes . . .
A new paper was released on the SSRN website: “Should a Multinational Firm Place Part of its Supply Chain in a Tax Haven?: Strategies to Enable International Tax Arbitrage,” by Masha Shunko (Purdue), Hung Do (Vermont) & Andy Tsay (Santa Clara) – SSRN
China’s State Administration of Taxation has instructed tax bureaus across China to survey companies regarding service fees and royalties paid to related parties between 2004 and 2013, to report back to the SAT on their findings, and to initiate audits of companies that have made suspicious payments, KPMG writes in an August tax alert. For details, see, KPMG. See also, EY.
The U.S. IRS on July 21 released an advance copy of Notice 2014-44, announcing that the government will issue regulations to prevent taxpayers from engaging in transactions following covered asset acquisitions that are intended to invoke the application of the statutory disposition rule under section 901(m)(3)(B)(ii) but avoid the purpose of section 901(m). Notice 2014-44
Luxembourg has brought two actions in EU General Court asking the court to annul European Commission decisions that direct Luxembourg to provide information on its intellectual property taxation scheme and to provide the Commission with a list of advance tax rulings issued in 2010, 2011, and 2012 involving cross-border transactions . . .
Australia, on July 11, announced a consultation on proposed legislation designed to ensure that foreign pension funds
. . .
The US Treasury Department has updated its FATCA website, reporting that Israel has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 30. Agreement
The Swiss Federal Council, on June 20, announced that Switzerland will initial an agreement with the European Union Economic and Financial Affairs Council outlining principles and intentions concerning Switzerland’s business taxation regime . . .
The Swiss Federal Council announced, on June 6, that the FATCA Act approved by parliament, together with the ordinance on disclosure obligations, will enter into force on June 30. Release
Mauritius Prime Minister, Dr Navin Ramgoolam and newly appointed Indian Prime Minister, Shri Narendra Modi, on May 28, announced . . .
Australia has begun sharing “information and intelligence” about multinational technology companies with five countries in an effort to crack down on tax avoidance. See, Jamie Smyth, Financial Times.
The U.K.’ s HM Revenue and Customs, on April 17, published draft guidance for proposed additions to the controlled foreign companies (CFC) rules in Part 9A TIOPA 2010, clause 286 of Finance Bill 2014. The guidance concerns new provisions that would switch off the full or partial exemption rules for loan relationship credits of a CFC where there is a main purpose of transferring profits from existing intra-group lending out of the U.K. Draft guidance (PDF 77K)
The European Commission, on December 3, announced its fifth investigation into whether a private tax ruling granted by an EU State to a multinational corporation amounted to illegal State aid. This time, a ruling granted to McDonald’s by Luxembourg . . .
The Swiss government on November 24 announced that double tax agreements signed by Switzerland and Cyprus, Iceland, Estonia, and Uzbekistan have entered into force. The goverment also announced that Switzerland signed . . .
Hong Kong’s Inland Revenue Department has announced on its website that Hong Kong signed at tax treaty with Romania . . .
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
European Commission President Jean-Claude Juncker told parliamentary committees January 17 that the EU should adopt rules governing private rulings . . .
Switzerland and Norway have signed protocol to amend their 1987 double taxation agreement to introduce an arbitration . . .
New Zealand’s government on August 18 released a discussion paper requesting feedback on a plan to extend the goods and services tax (GST) to cross-border services and intangibles supplied to its residents, such as e-books, music, videos, and software purchased. . .
“Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information about that unit,” write Bloomberg’s Alex Barinka and Jesse Drucker. See: Bloomberg Business
The US Treasury Department has updated its FATCA website, reporting that Georgia has signed a Model 1 intergovernmental . . .
Tax officials at a June 6 OECD consultation suggested that draft guidance on cost contribution arrangements (CCAs) will be modified to clarify how to value CCA contributions. Officials also requested stakeholder feedback to help refine aspects of draft guidance on transfer pricing for hard-to-value . . .
The US Treasury Department has updated its FATCA website, reporting that the Holy See has signed a Model 1 intergovernmental agreement (IGA) with the US as of June 10. The text of the agreement is available. See, FATCA IGA – Holy See.
The South Africa National Treasury announced in a June 5 media statement that the government intends to introduce draft legislation providing that issuance of shares by a South African resident company as consideration . . .
The Australian government on May 11 announced plans to beef up antiavoidance rules to tax multinational profits diverted from Australia and to propose laws to ensure that offshore suppliers of digital products and services pay goods and services tax (GST). The proposals will be unveiled in the government’s . . .
The UK’s HM Revenue Customs on April 13 notified UK financial institutions that UK FATCA guidance will be amended to remove the requirement to file nil returns and to no longer require FATCA reporting by most holding and treasury companies. HMRC said the US IRS has changed its . . .
The United Nations Conference on Trade and Development (UNCTAD) on March 26 released a draft report that concludes that developing countries are losing about $100 billion every year from MNE tax avoidance through use of offshore hubs. Some 30% of cross-border corporate investment . . .
The US IRS has released on its website the text of a Model 1 FATCA intergovernmental agreement (IGA) signed with Kosovo. The agreement is effective as of January 7 . . .
Hong Kong and Germany completed their second round of tax treaty negotiations on March 6, according to Hong Kong’s Inland Revenue Department. This would be the first comprehensive double . . .
India’s budget, released February 28, introduces several tax changes of interest to business, including a deferral of planned general antiavoidance rules (GAAR), clarification of rules on indirect transfers of Indian assets, and the introduction of proposals to cut the corporate tax rate and widen the corporate tax base. In a . . .
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
