The European Commission on March 26 made a formal request to Belgium to amend dividend taxation rules to comply with the parent-subsidiary directive. The Belgian law does not allow . . .
The European Commission on March 16 released the first report of the Expert Group on Automatic Exchange of Financial Account . . .
taly and Switzerland on February 23 signed a protocol to their double tax treaty agreeing to the OECD standard for the exchange of information on request, the Swiss government has announced. The countries also signed a roadmap for continued dialog on financial and tax matters . . .
The US IRS on December 24 released final regulations, TD 9707, under sections 6038A and 6038C of the tax code providing that the Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” must be filed in all cases only with the . . .
The US IRS on December 16 has updated the list of jurisdictions with which the US has an information exchange agreement for purposes of the bank deposit interest reporting requirements of sections 1.6049-4(b)(5) and 1.6049-8(a) of the Income Tax Regulations. The guidance . . .
Spain has enacted major tax reform, including corporate tax reform, effective January 1, 2015, writes Deloitte in a December 2 alert. The corporate tax changes include a reduction in tax rates for 2015 and 2016, anti-hybrid rules and . . .
Russian President Vladimir Putin on November 24 signed the “deoffshorization” law, requiring Russian companies and individuals to pay tax on undistributed controlled foreign corporation (CFC) profits. The new law, effective January 1, also contains provisions clarifying the tax residency status of foreign legal entities, adds new rules on indirect transfers of immovable property through share transfers, and requires that a recipient of treaty benefits be the beneficial owner of the income.
UPDATE (11/28/2014): The new law contains a few changes from earlier drafts, writes EY in its Russian Tax Brief, released November 27. For analysis of the changes, see EY.
The US IRS in Chief Counsel Memorandum 201444039 released October 31 concluded that foreign tax redeterminations with respect to a controlled foreign corporation’s (CFC) pre-1987 accumulated profits, regardless of when made, are accounted for by adjusting . . .
The UK’s HMRC has released a revenue and customs brief concerning the impact in the UK of the European Court of Justice judgment in the Skandia America Corp. case . . .
The UK on Sept. 29 released the FATCA schema and supporting documents in advance of the availability of the FATCA service. See, release.
The European Commission, on August 22, took another step toward addressing concerns that the Netherlands’ corporate tax exemption for Dutch public enterprises violates state aid, asking . . .
Sri Lanka’s Ministry of Finance and Planning, on August 4, announced that R.M.R.W. Manchanayake has been appointed to the post of Acting Commissioner General of the Inland Revenue Department. Release
Six witnesses are scheduled to speak at a US Senate Committee on Finance hearing on international tax, set for July 22. The hearing is expected to address, among other issues, US legislators’ concerns about a recent spate of US multinational inversions undertaken to avoid U.S. tax.
Slated to testify are Robert B. Stack . . .
DLA Piper has announced that Hervé Israël has joined DLA Piper’s Paris office as a tax partner.
Hervé was previously partner and head of the international tax group at Holman Fenwick Willan. Release
President Obama, on June 19, nominated Cary Douglas Pugh as a Judge to the United States Tax Court. Pugh is currently with at Skadden, Arps, Slate, Meagher & Flom, L.L.P. She previously served as Tax Counsel for the Senate Committee on Finance. Release
The OECD’s Working Party 6 (WP6) has decided to not add materiality thresholds to OECD guidance on transfer pricing documentation and country-by-country reporting, WP6 delegates said on May 19, during a day-long consultation on a draft of the guidance.
US delegate, Michael McDonald, said that WP6 decided it can not provide any explicit guidance on materiality other than to say that materiality is a local country issue.
“Quantitative materiality thresholds are very difficult. . .
Influential chair of the UK Public Accounts Committee, Margaret Hodge, has urged British shoppers to boycott Amazon following revelations that the online retailer paid only £4.2m in tax last year on sales of £4.3bn, according to an article by Juliette Garside, The Guardian. See also, Peter Campbell, Daily Mail; Sarah Shaffi, The Bookseller; Gideon Spanier The Independent; Sean Martin International Business Times UK
The European Union’s Joint Transfer Pricing Pricing Forum has published profiles of the transfer pricing policies of all EU member states, including competent authorities’ contact details and other information. JTPF Country Profiles
Economist Nancy Voth, Ph.D., CFA, has WTP Advisors’ Transfer Pricing Practice in Minneapolis. Release
The India government, in a notice dated December 1, announced that a tax treaty with Thailand . . .
Japan’s Ministry of Finance has advised that on November 30 Japan and Qatar exchanged diplomatic for the entry into force of the Japan-Qatar tax treaty, signed . . .
The Australian Taxation Office (ATO) on November 22 released guidance on a proposed antiavoidance law being considered by Parliament that is designed to combat the use of artificial or contrived arrangements by multinationals to avoid attribution of profits to Australian permanent establishments. Also, Australia’s Board of Taxation . . .
The EU Joint Transfer Pricing Forum has released statistics for 2014 on EU nation advance pricing agreements (APAs) and on pending . . .
The G-20 finance ministers have endorsed the final reports responding to the OECD/G20 base erosion profit shifting (BEPS) plan . . .
The EU Commission will address the tax bias that favors debt over equity as a part of its proposal for an EU-wide common consolidated corporate. . .
The Isle of Man signed a tax information exchange agreement (TIEA) with the Cayman Islands on September 22 . . .
Australia’s Treasurer Joe Hockey on September 17 announced that Australia intends to commence tax treaty negotiations . . .
India’s income tax department has released a detailed guide for financial institutions to assist with the implementation of FATCA and the common reporting standard for the automatic exchange of information. The 30-page guide, issued August 31, covers the types of institutions that must report, the types . . .
The European Commission has announced that its current view is that Belgium’s excess profits tax ruling system provides for a selective advantage tantamount to State aid, and has requested stakeholder comments on this determination by July 5. According to the Commission, about 50 companies have used the program to reduce . . .
The UK and Kosovo on June 4 signed an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital. See:, Treaty.
The OECD on May 22 released a revised discussion draft under the OECD /G20 base erosion and profit shifting (BEPS) plan dealing with the prevention of tax treaty abuse. The draft, prepared by Working Party 1 of the OECD’s Committee. . .
The US IRS, in a private letter ruling released May 8, has concluded that royalties paid to a foreign corporation for the broadcasting of television channels are exempt from US income tax under the royalties article of a tax treaty. See, PLR 201519003.
Switzerland’s Federal Council, on April 22, announced that it has instructed the Federal Department of Finance to create the legal basis for rules that would provide a flat-rate tax credit for foreign companies’ permanent establishments in Switzerland which have their registered office in a country with which Switzerland has a double taxation agreement. The credit would alleviate double . . .
The OECD’s Pascal Saint-Amans sought to allay Australian lawmakers’ fears that the OECD will fail in its mission to curb tax avoidance through its base erosion and profit (BEPS) plan during an Australian senate hearing, as the senators weighed whether they should support immediate unilateral tax measures to protect . . .
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