The Indian government on May 21 released draft transfer pricing rules that would introduce the concept of a range for determining arm’s length price as well as allow the use of multiple year data for comparability purposes. The rules . . .
New Zealand’s government on May 7 released a white paper which makes a variety of recommendations on ways to close loopholes in the 10 percent non-resident withholding tax on related party debt . . .
Australia’s Treasury on April 28 released an exposure draft of tax legislation designed to plug loopholes in the consolidation regime. According to a release accompanying . . .
The Isle of Man was dropped from Italy’s tax blacklist regarding deductibility of costs as of April 1, the Isle of Man government announced on April 17. The change was made on account of a new Italian law which provides that jurisdictions that have exchange of information arrangements . . .
Mauritius and Austria have signed a tax information exchange agreement (TIEA) according to a release posted on a Mauritius government website March 13. The agreement was . . .
Liechtenstein and United Arab Emirates have initialed a tax treaty, Liechtenstein’s Ministry for General Government Affairs announced March 4. The treaty largely follows the OECD Model Convention and provides for cooperation on tax matters between the tax authorities. The agreement also clarifies the tax treatment of asset structures . . .
Japan and Qatar on February 20 signed a tax treaty in Tokyo, the Japanese Ministry of Finance has announced. Under the agreement, taxation in the source country on dividends is reduced to 5 percent for corporate shareholders that hold at least a 10 percent interest, and is 10 percent in other cases. Taxation . . .
WTP Advisors announced February 4 that Kash Mansori, an economist and transfer pricing specialist, has joined the firm’s North Carolina office. Mansori previously had his own consulting practice, and has worked for Ernst & Young and Experis Finance. He was also an economics professor at Colby College where he conducted research on transfer pricing, international trade, and international finance.
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force, reports CMS Bureau Francis Lefebvre in a January 9 tax alert. Among the new tax law changes is a broadening of the scope of tax consolidation to include . . .
Five US senators have urged the IRS to take action to stop MNEs from establishing holding partnership structures to avoid paying taxes on recognized gain in an inversion, like the partnership structure used in the Burger King and Tim Hortons merger. . .
The US IRS, in a private letter ruling released December 12, granted a corporation prospective consent to change to the elective method for measurement and timing of employee stock options, restricted shares, and restricted share units pursuant . . .
An OECD discussion draft released December 16 proposes to modify OECD transfer pricing guidelines to clarify that the arm’s length price for commodities can be determined by reference to a commodity’s quoted or publicly available prices. The guidance also sets the shipment date as the default pricing date. . . .
Fearghus Carruthers, head of tax at Shire Pharmaceuticals, has been added to the list of witnesses scheduled to testify at a December 8 UK House of Commons Public Accounts Committee hearing on the role of large accounting firms in multinational tax avoidance. Carruthers will join . . .
The Belgian government entered into a coalition agreement October 9, agreeing to limit the notional interest deduction regime for financial institutions and insurance companies and to modify the stock exchange tax, among other tax measures, writes Alain Huyghe, Philippe Lion, Luc Meeus, and Géry Bombeke of Baker & McKenzie in an October 10 report. For details, see Baker & McKenzie.
The Isle of Man has been removed from Republic of Colombia’s blacklist as of October 7 pursuant to Decree 1966/2014, according. . .
The US IRS on October 10 released Chief Counsel Advice 201441015, concluding that no portion of a controlled foreign corporation’s pre-1987 foreign income taxes are eligible to be deemed paid, including additional amounts paid in 2007 as a result of a redetermination of foreign tax. Chief Counsel Advice 201441015
The OECD on Oct 1 released a revised timetable for stakeholder consultation in its base erosion profit shifting (BEPS) project. Revised timeline, release
Citing OECD pressure to reform its tax system, Switzerland is considering abolishing existing tax arrangements that no longer meet international tax standards, primarily the cantonal tax statuses for holding, domiciliary, and mixed companies. New rules would be added, however, to enhance the country’s “appeal as a tax location,” including a royalty box and. . .
The Slovak Ministry of Finance on August 20 released new guidance specifying minimum transfer pricing documentation requirements, writes EY in a Sept. 16 Global Tax Alert. For discussion, see EY.
Switzerland and Estonia, on August 25, signed a protocol to amend their double taxation agreement.
Under the agreement, interest and royalty payments are exempt from withholding tax. Dividends are also exempt from withholding tax if the company receiving the dividend holds a stake of at least 10 percent in the capital of the distributing company for at least one year. In other cases, the withholding tax rate for dividend distributions is 10 percent.
The agreement also provides for the exchange of information upon request in accordance with the currently applicable international standard.
The agreement must be approved by parliament in both countries before it can come into force. Release
The Swiss Federal Council, on August 20, approved tax information exchange agreements with Andorra, Greenland, San Marino, and the Seychelles. The agreements will be submitted to parliament for approval. press release
New and updated FATCA frequently asked questions (FAQs) have been posted to the FATCA Website, as follows . . .
Ernst & Young LLP announced July 17 that Richard McAlonan, Jr. has joined the firm as director of national tax transfer pricing controversy in Washington, DC. McAlonan will also act as the Americas director of advance pricing agreements (APAs). McAlonan previously. . .
The Canada Revenue Agency (CRA) has released its Mutual Agreement Procedure (MAP) Program report for the
. . .
Dorsey & Whitney LLP, on May 7, announced that solicitor and chartered accountant, Michael Cashman, has joined the firm’s London office as a partner in the Tax Group. Cashman works on UK and international transactional tax matters. Release
The European Court of Justice (ECJ), on April 10, ruled that Polish tax laws that exempt from withholding tax dividends paid to investment funds located in Poland and other EU countries, but that do not exempt dividends paid to funds located outside the EU, may be invalid because the laws restrict free movement of capital.
As a result, U.S. investment fund, Emerging Market Series of DFA Investment. . .
The OECD has revised the dates when discussion drafts will be published and public consultations held in relation to the September 2014 BEPS outputs. OECD
India and South Korea have signed a memorandum of understanding (MoU) agreeing to suspend the collection of taxes while mutual agreement procedure . . .
See: The Effect of Profit Shifting on the Corporate Tax Base in the United States and Beyond, by Kimberly Clausing: SSRN
Japan and Chile have agreed in principle on a tax treaty, Japan’s Ministry of Finance announced . . .
Hong Kong’s Inland Revenue Department has released the text of a tax treaty signed with Italy on January 14, 2013 . . .
Christian Aid has received a mixed feedback from its survey of the 100 largest companies on the London Stock Exchange regarding whether to the UK should adopt public CbC reporting. See: Christian Aid.
Indonesia’s finance minister on August 18 issued tax regulations offering a tax holiday to businesses in nine strategic sectors for up to 20 years, writes The Jakarta Post. See: The Jakarta Post. See also: Ministry of Finance release, World Finance, Bloomberg, The Business Times.
Hong Kong on July 17 published in its official gazette Inland Revenue (Amendment) (No.2) Ordinance 2015, which extends the profits tax exemption for offshore funds to private equity funds. To qualify for the profits tax exemption, offshore private equity . . .
The Society of Indian Law Firms has filed complaints with the Bar Council of Delhi alleging that PwC, Deloitte, KPMG, EY, and their executives have engaged in unauthorized . . .
It is “imperative” that the US change its international tax system to a dividend exemption regime coupled with “robust and appropriate” base erosion rules, concluded the co-chairs of a US Senate bipartisan working group in a July 8 report. Senator Rob Portman (R-Ohio) and Senator Chuck Schumer (D-NY) said in the. . .
The OECD has asked transfer pricing officers in multinational enterprises to participate in an online survey on transfer pricing comparability data . . .
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