The OECD on June 18 released 65 public comments on a discussion draft under the OECD/G20 base erosion profit shifting (BEPS) plan dealing with tax treaty abuse. The draft, prepared by Working Party 1 of the OECD’s Committee on Fiscal . . .
Final US anti-inversion regulations published June 4 retain the 25 percent bright-line test of temporary and proposed versions of the regulations for determining if an expanded affiliated group (EAG) is considered to have substantial business activities in a foreign country. The regulations . . .
The US Senate Finance Committee on April 30 released comment letters submitted to Senate working groups that are currently analyzing US tax reform options. The comments were submitted in . . .
The UK’s HM Revenue and Customs, on March 30, released interim guidance on its new diverted profits tax, set to go into effect April 1. The guidance uses practical examples to explain . . .
The UK government has released regulations implementing automatic exchange of information under the European Union Revised Directive on Administrative Cooperation and under the Multilateral Competent Authority Agreement implementing the Common Reporting Standard. The regulations, released March 24, also make minor changes to existing rules implementing the UK’s FATCA agreement . . .
Irish Revenue on March 12 released guidance on how it will implement spontaneous exchange of tax ruling information with EU Member States. The directive applies with immediate effect. As a member of the EU, Ireland is subject to . . .
UK businesses must adjust their accounting for VAT on intragroup supplies of services beginning in 2016 to follow the European Court of Justice’s ruling in Skandia America, HMRC said in a policy briefing released February 10. . . .
The European Commission will be giving up its state aid investigation into EU patent box regimes because its 2008 decision to approve Spain’s patent box created the expectation that the programs are legal, writes Victoria Slind-Flor of Boomberg, in a February 3 article, quoting a Commission official. See, Bloomberg.
The OECD on December 18 released four more discussion drafts addressing aspects of the OECD/G20 base erosion and profit shifting (BEPS) action plan. The drafts concern the application of VAT/GST to business-to-consumer (B2C) supplies of services and intangibles, seek to limit BEPS through interest deductions, and propose ways to improve the mutual agreement procedure (MAP) dispute resolution process. . . .
US Senator, Orrin Hatch, expected to be the next Chairman of the Senate Finance Committee, released a report December 11 which calls for the US to adopt a territorial tax system and suggests that the US consider adopting a patent or innovation box. The report . . .
New Zealand expects in 2015 to negotiate tax treaties or protocols with Korea, Australia, Norway, Slovak Republic, China . . .
India will never agree to mandatory arbitration and will make its view known at the G-20 leaders summit, reports Shruti Srivastava of the Financial Express in a November 13 article, quoting an unnamed senior official. Srivastva also quotes the official as stating that India “will raise the issue of defining ‘significant digital presence,’ which may include the number of bytes used, number of users, or the value addition done in a country.” The summit begins November 15 in Brisbane, Australia. For more, see Financial Express.
Indian tax authorities have lodged an appeal in the Supreme Court contesting the February 5 decision of the Delhi High Court in e-Funds IT Solutions/e-Funds Corp v. DIT, reports the Financial Express in a November 5 article. In e-Funds, the Delhi High Court concluded . . .
A. Duane Webber will chair Baker & McKenzie’s Global Tax group, the firm announced at its annual meeting held October 7. Webber is based in Washington, DC. Release.
HM Treasury’s David Gauke on October 3 said the UK does not support the the adoption of the nexus approach described the OECD’s interim report on harmful tax practices to determine if intellectual property regimes reward “substantial activities” . . .
Draft UK regulations released on October 3 under the Promoters of Tax Avoidance legislation in Finance Act 2014 exclude from the definition of “promoter” the . . .
China’s General Office of the State Administration of Taxation (SAT) in a Sept 15 English-language news release described the contents of a recently issued SAT Announcement “Reporting of Information on Overseas Investments and Income by Tax-resident Enterprises.”
The Announcement . . .
Treasurer Joe Hockey in a Sept. 4 release said that he has asked the Commissioner of Taxation to examine whether location specific profits are being generated in Australia on account of the high prices multinationals charge to consumers and, if so, whether multinationals are appropriately allocating these profits to Australian operations under the transfer pricing rules.
“Australian consumers often pay much higher prices compared to United States . . .
The government of Chile, on August 9, released a revised Tax Reform Bill, which incorporates 278 modifications to the bill originally submitted to Congress on April 2, writes KPMG Chile in an August tax alert. Included are significant changes to the corporate tax regime and rates, to thin capitalization rules, revisions to the treatment of goodwill amortization, and anti avoidance rules. For an analysis of the revisions, see KPMG (PDF 80 KB)
The European Commission, in a July 24 website post, announced it has extended the deadline for submitting applications to serve as a VAT Expert Group member until Sept. 12. Website, Call for Applications (22KB), Prior coverage.
Vietnam and Turkey signed a double tax avoidance agreement during July 6-9 negotiations held in Turkey, reports Vietnam Breaking News.
The Australia Taxation Office (ATO) has released draft guidance on how the ATO will administer and how financial institutions will comply with the FATCA intergovernmental agreement (IGA) between Australia and the United States. Comments on the draft are requested by July 18. Draft guidance
The Slovak Ministry of Finance is considering re-introducing thin capitalization rules into Slovak tax law, according to a June 16 report by KPMG.
An ITAT ruling, Bharti Airtel, has concluded that a corporate guarantee is not an international transaction under the Indian transfer pricing regulations, according to Vijay Iyer, EY, in an article submitted to the Business Standard
The government of Cyprus on December 11 announced that it has signed a protocol . . .
UAE and Norway officials signed an agreement on exchange of information for tax purposes during . . .
The OECD has announced that it will present webcasts on October 5 on the contents of the final reports under the . . .
The US IRS has announced that the FATCA regulations will be amended to extend transition rules for gross proceeds, foreign passthru payments, limited branches and limited . . .
Cyprus’s Ministry of Finance announced September 8 that it has agreed with the government of Ukraine to conclude a protocol to the countries’ November 2012. . .
In a significant blow to the IRS, the US Tax Court has invalidated 2003 cost-sharing regulations that require related parties to share stock-based compensation costs in qualified cost-sharing agreements, finding that the regulations do not meet the standard of reasoned . . .
The OECD on June 19 released 42 public comments on a discussion draft on action 8 of the OECD/G20 base erosion profit shifting (BEPS) plan dealing with hard-to-value intangibles for purposes. . .
European Court of Justice Advocate General Juliane Kokott, in an opinion issued June 11, concluded that France has violated freedom of establishment principles through a law that only gives domestic companies the opportunity to join a French group and . . .
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