The OECD on May 5 released public comments to an OECD discussion draft that provides recommendations on how countries can design effective controlled foreign companies (CFC) rules to combat base erosion and profit shifting (BEPS). Sixty-two comments were released in response to the guidance, issued April 3 in response to action 3 of the OECD/G20 BEPS. . .
The EU Joint Transfer Pricing Forum (JTPF) has proposed modifications to the EU Arbitration Convention and revised Code of Conduct to better accommodate transfer pricing disputes. in a report released on its website, the JTPF . . .
Irish Revenue on April 22 released the text of a tax treaty signed by Ireland and Zambia on March 31. The agreement is . . .
The G20/OECD base erosion profit shifting (BEPS) project is in its “decisive stages,” with only six months remaining until the 15 BEPS deliverables must be completed, Angel Gurría Secretary-General of the OECD said at a meeting of World Bank Group and International Monetary Fund officials, G20 Finance Ministers, and Central Bank Governors held . . .
The Seychelles Revenue Commission has released a circular that provides guidance to financial institutions subject to FATCA reporting obligations. The guidance describes the information . . .
Yuval Navot, a partner with Herzog, Fox & Neeman, Tel Aviv, analyzes draft guidance released by the Israel Tax Authority on April 2 which specifies when a foreign Internet firm has a permanent establishment in Israel giving rise to corporate taxation and has business activity in Israel requiring VAT registration.
New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on March 24 concerning reporting deadlines and nil reporting. . .
Masao Yoshimura, an Associate Professor of Tax Law at Hitotsubashi University’s Graduate School of International Corporate Strategy, analyzes a Japanese government proposal passed by the Lower House March 13 which would impose consumption tax on the supply of digital services by foreign providers. . .
Ireland’s Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle (“ICAV”), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .
Chris Ball, Adele Townsend, and eight other tax specialists left Pitcher Partners to join BDO’s tax team in Brisbane on February 2, BDO has announced. Ball and Townsend join . . .
The US has released the text of an agreement signed by competent authorities of the US and Kazakhstan which concerns the eligibility of entities that are treated as fiscally transparent under a double tax agreement signed by the countries
. . .
The OECD on January 12 released public comments to discussion drafts under the OECD’s base erosion and profit shifting (BEPS) action plan which deal with the prevention of tax treaty abuse and with the artificial avoidance of permanent establishment (PE) status. Eighty comments were released on the tax treaty . . .
The Swiss Federal Council on December 17 submitted for consultation a bill proposing to replace its current debtor system of withholding to a system based on a paying agent principle. The consultation will run until March 31, 2015. See, release.
The Australian Taxation Office (ATO) on December 17 released a final ruling and two practice statements dealing with transfer pricing documentation and penalties. Final ruling TR 2014/8 outlines . . .
The EU Commission’s new president, Jean-Claude Juncker, on November 27, survived a no-confidence vote in European parliament brought on account of the ‘Lux leak” revelations that Luxembourg helped scores of multinationals avoid tax while he was prime minister. The censure motion . . .
The European Commission’s Joint Transfer Pricing Forum (JTPF) has released draft papers on improving the functioning of the EU arbitration convention and the EU code of conduct on transfer pricing documentation. The drafts, released in November, were . . .
The OECD will invite some developing nations to participate in OECD Committee on Fiscal Affairs (CFA) meetings, will hold regional consultations, and will work on capacity development in an effort to increase developing nation input in the OECD/G-20 base erosion profit shifting (BEPS) plan decision-making . . .
UPDATE: Philippines Joining OECD Committee on Fiscal Affairs: The Philippines will join the OECD Committee on Fiscal Affairs to work on a global response to BEPS beginning January 2015, the Philippines Department of Finance announced November 14. See, Philippines release.
Agreements between Switzerland and Jersey, Guernsey, and the Isle of Man regarding the exchange of information on tax matters have entered into force. The agreements . . .
Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group services. The guidance was released in response to Action 10 of the OECD Base Erosion and Profit Shifting (BEPS) plan, which directs the OECD to develop transfer pricing rules or special measures “to provide protection against common types of base eroding . . .
Ireland is expected to announce on October 14 that it will phase out the “Double Irish” tax loophole, reports Sam Schechner and Lisa Fleisher, The Wall Street Journal. See also, Padraic Halpin, Reuters and Arthur Beesley, Irish Times.
The European Commission on Oct. 7 announced that it has opened an in-depth investigation into whether Luxembourg granted private rulings to an Amazon subsidiary with too favorable terms, potentially violating EU rules on state aid.
The 2003 tax ruling, which is still in force, sets a methodology for the payment of a tax deductible royalty by Luxembourg-based Amazon EU Sàrl to a related limited liability. . .
Australia’s Senate on Oct 2 voted to conduct hearings on aggressive tax minimization by corporations registered in Australia and by multinational corporations operating . . .
Macau’s Financial Services Bureau on Sept. 26 announced its support for the common reporting standard for automatic exchange of financial account information. Procedures will be initiated to amend Macua’s laws to ensure timely compliance with the new standard, the agency said. Release.
The South African Revenue Service, on August 14, released a binding private ruling involving the proposed restructuring of a multinational group, concluding that a German Kommanditgesellschaft is a company for South African tax purposes and that the proposed restructuring did not give rise to tax, including capital gains tax. BPR 178
Hong Kong and Korea, on July 8, signed an agreement for the avoidance of double tax and fiscal evasion with respect to taxes on income .
Under the agreement, the Korean withholding tax on interest
. . .
The Australian Taxation Office (ATO), in TR 2014/3 released June 11, has ruled that a company
. . .
The Australian Government, on May 4, released draft legislation that would give the revised Australia-Swiss tax treaty and accompanying protocol, signed . . .
An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.
Mark Konza, ATO Deputy Commissioner, International, said that Australia was “currently involved in a cooperative compliance approach” with five other nations. The collaboration led to the production of an
Members of the OECD task force charged with crafting rules to address the tax challenges of the digital economy still disagree on fundamental issues associated with the project. Speaking April 23, Edourad Marcus, co-chair of the task force, said members are still debating whether they should recommended modifications to the corporate income tax through. . .
An anti-avoidance rule that would limit double tax relief, under consideration in U.K. Finance Bill 2014, sweeps in too many transactions and should be modified to require a tax avoidance purpose, according to KPMG’s UK office. The proposal limits double tax relief claimed with respect to loan relationships, derivatives, and intellectual property non-trading credits. KPMG
Rep. Charles Boustany (R-La.) will head of the tax policy subcommittee of the Ways and Means Committee of the US House of Representatives . . .
Tax officials from 104 jurisdictions attending the November 5-6 meeting of the OECD’s Global Forum on VAT endorsed new OECD VAT/GST guidelines on the treatment of cross-border trade in services and intangibles and suggested that the OECD next consider taking on several new VAT . . .
Uganda on November 4 became the 90th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has . . .
The European Commission today announced that it has determined that advance pricing agreements granted to a Starbucks subsidiary by The Netherlands and to Fiat subsidiary by Luxembourg were illegal state aid because they sanctioned the allocation of too little profit to activities in those countries and . . .
The European Council on October 6 reached unanimous agreement on a directive that would require EU states to automatically exchange information about private tax rulings with other EU states. The agreement, reached at an ECOFIN meeting in Luxembourg, obliges . . .
Revenue Minister Todd McClay on September 3 announced that the New Zealand goverment will introduce tax legislation early next year providing that there will be no income to a debtor upon the cancellation of a debt owed to a . . .
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