The European Parliament’s Legal Affairs committee, on May 7, backed a draft law that would require large firms and public-interest entities to publicly report information on a country by country basis, with a goal of strengthening transparency of tax strategies . . .
The Inland Revenue Authority of Singapore (IRAS) on April 17 updated information on its website concerning FATCA reporting. Changes were made to information on . . .
Mauritius was removed from Italy’s tax blacklist with the entry into force of the Italian Stability Law 2015, the Mauritius government announced April 15. The development follows efforts undertaken by Mauritius . . .
Tax officials at a March 19 consultation on draft revisions to OECD transfer pricing guidelines expressed interest in adopting a special measure proposed in the draft that would address hard-to-value intangibles. Officials also discussed the weight that should be accorded a related party . . .
The Tax Court of Canada has concluded that TDL Group, a Canadian subsidiary of Wendy’s International Inc., the US restaurant chain, may not deduct $10 million (7.8 million USD) interest on loans from its parent in 2002. TDL used the loan to acquire additional shares of its wholly owned US subsidiary, Tim Donut US Limited, Inc., which then lent
The European Commission on February 18 announced that it will present a tax transparency package in March which will include a legislative proposal for the automatic exchange of information on tax . . .
Switzerland and Liechtenstein have agreed to the terms of a revised double tax treaty and expect to sign the agreement this summer, Switzerland’s Federal Department of Finance (FDF) announced on February 5. The agreement, which would replace . . .
Hong Kong’s Inland Revenue Department, on January 29, released revised forms for companies, partnership, trusts, and other entities to apply for a certificate of resident status for purposes of claiming tax treaty . . .
The UK on January 13 released an updated schema and supporting documents for software developers working on the FATCA service . . .
The Ecuadorian Internal Revenue Service has set up a new system to provide advance rulings on a company’s transfer pricing methodology, writes EY in a December 17 report. For discussion, see EY.
The European Commission on November 14 published its preliminary opinion that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary constitutes illegal state aid. The inquiry, first announced in June, is one of four state aid investigations recently initiated by the Commission clamping down on EU states that grant sweetheart deals to . . .
New German regulations on allocation of profit between head office and permanent establishments were published in the Federal Law Gazette on October 17, 2014, and are now applicable to tax years beginning after December 31, reports PwC. The regulations provide detailed rules on the application of the Authorized OECD Approach (AOA), which became effective in Germany in 2013. For analysis of the new regulations, see PwC.
The US IRS has posted new versions of forms and instructions to incorporate FATCA reporting requirements, as . . .
Australian Greens Leader Christine Milne has announced that her party will introduce on October 28 the Corporations Amendment (Publish What You Pay) Bill 2014, which will require reporting of payments made by Australian-based extractive companies to foreign governments on a country-by-country and . . .
The Isle of Man Treasury announced on October 21 that the “Agreement for the Exchange of Information Relating to Tax Matters” signed by the Isle of Mann and Indonesia on June 22, 2011, entered into force on September 22. Release.
Major Chilean tax reform legislation was published in the Official Gazette on September 29, introducing new measures for computing shareholder-level income taxation, amendments to thin capitalization rules, rate increases, and the introduction of general antiavoidance rules, among many other changes, writes PwC in an October 3 report. For analysis of some of the most important tax changes, see PwC.
The European Commission will publish this week the formal letter the Commission sent to Ireland in June setting out its preliminary view that Ireland violated state aid in granting private tax rulings to Apple . . .
The US IRS, on Sept. 10, announced that it will amend reg. sec. 1.1298-1T of the passive foreign investment company (PFIC) regulations to provide that, generally, a US person that holds PFIC stock that is marked-to-market under a non-section 1296 mark-to-market regime, such as under section 475(f), will not be subject to the reporting . . .
Bitcoin is not foreign currency but is an asset subject to capital gains tax, so transacting in bitcoin is similar to bartering, the Australian tax office (ATO) concluded in a package of draft guidance released on August 20.
The ATO said that businesses receiving bitcoin as payment for goods or . . .
India’s government will amend its tax regulations to allow for the roll back of advance pricing agreements (APAs) to the previous four years, Finance Minister Arun Jaitley announced during a July 10 speech outlining the 2014-15 Union Budget.
The new rules, long sought by international firms, could assist in resolving India’s huge backlog of transfer pricing disputes, permitting concepts agreed to in an APA between the government and a taxpayer to apply to previous tax years.
Jaitley said the government will also introduce a “range concept” to determine arm’s length price for transfer pricing, though arithmetic mean . . .
The Tax Court of Canada, on June 10, ruled in Marzen Artistic Aluminum Ltd. that marketing fees paid to Marzen’s wholly owned subsidiary, Starline International Inc (SII), were not arm’s length.
SII was incorporated in Barbados to act as Marzen’s agent for sales of windows in the U.S.
. . .
Philippines tax authorities have accelerated work on advance pricing agreement (APA) guidelines and are working on transfer pricing documentation and audit guidelines, writes Quantera Global, in a June 3 post to its website. For details, see Quantera Global.
Switzerland’s Federal Counsel. on April 30, announced that the government will prepare a consultation draft on corporate tax reform. The consultation will be based on a government report released December 2013 and will last until September 2014 . See, Press Release.
The OECD has published 77 comments received in response to its draft on preventing treaty abuse, which is Action 6 of the base erosion profit shifting initiative. Comments (PDF 6.59 MB)
The Permanent Subcommittee on Investigations has scheduled a hearing, “Caterpillar’s Offshore Tax Strategy” on Tuesday, April 1, 2014, at 9:30 a.m., in Room 106 of the Dirksen Senate Office Building.
The Subcommittee will continue its examination of the structures and methods employed by multinational corporations to allocate income outside of the United States and how such activities are affected by the Internal Revenue Code and related regulations.
Witnesses will include representatives of Caterpillar Inc. and PricewaterhouseCoopers LLP, as well as tax experts. A witness list will be available Friday, March 28, 2014.
Source: U.S. Senate Permanent Subcommittee on Investigations
The South African Revenue Service on December 15 issued draft rules requiring companies that have consolidated South African turnover of R1 billion and above to keep . . .
US lawmaker, Rep. Mark Pocan (D-WI), introduced two tax bills November 9 designed to take away tax benefits of corporate inversions . . .
Walter Nagel has joined publisher Gannett as its vice president and chief tax officer, leaving . . .
The European Commission on September 28 published its annual overview of recent tax reforms . . .
The company said the dispute is over income received from licensing its products to related parties located in foreign markets from 2007–2009. See: Wall Street Journal. More: Forbes, Business Insider, Market Watch.
Tax justice campaigner Richard Murphy has been appointed Professor of Practice in International Political Economy at City University London. Murphy will be teaching a course titled Economics in the Real World. See: Tax Research UK.
US House Ways and Means Committee members Charles Boustany, Jr., (R-La.) and Richard Neal (D-Mass.) on July 29 released draft innovation box legislation that would lower the tax rate on income from intellectual property to about 10 percent, arguing that the proposal is needed to keep research . . .
Countries failed to agree to a proposal to upgrade the UN Committee of Experts on International Cooperation in Tax Matters to a more powerful UN intergovernmental body during the United Nations Third International . . .
India and Mauritius have reached consensus on the conclusion of a tax treaty, the Mauritian government announced July 1. Agreement was reached yesterday following discussions held by a joint working group of Indian and Mauritian officials . . .
Bermuda is seeking immediate removal the European Commission’s list of non-cooperative jurisdictions as both Latvia and Poland have now confirmed that they have taken Bermuda off their national tax blacklists. Poland and Latvia have contacted the European Commission to confirm Bermuda’s. . .
The US Treasury Department updated its FATCA website reporting that the UAE has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 17. The text of the agreement is available. The countries, on June 10, 2014, agreed . . .
The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.
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