Asia-Pacific
Australia releases draft law to implement common reporting standard
Australia on September 18 released draft legislation to implement the OECD’s Common Reporting Standard for the automatic exchange of financial account . . .
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Europe
Ireland likely to lose EU state aid case involving Apple – Bloomberg Business
“Ireland will probably face censure from European authorities within months in relation to its tax dealings with Apple Inc.,” write Gaspard Sebag and Joe Brennan of Bloomberg Business, quoting unnamed sources. See: Bloomberg Business.
Americas
US Treasury should suspend work on regulations implementing country-by-country reporting say Ryan and Hatch
US Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew asking Treasury stop work on a regulation project to . . .
Americas
Canada signs 31 APAs in FY 2014/2015
Canada signed 31 advanced pricing arrangements (APAs) in FY 2014/2015, the most in five years, according to data released August 20 by the Canadian Revenue Agency (CRA). A total of 29 bilateral and 2 unilateral . . .
Asia-Pacific
China and South Korea sign bilateral APA
China and South Korea have signed a bilateral advance pricing agreement, the Chinese goverment announced in a June 23 English-language release. The signing took place during a Sino-South Korea tax commissioners meeting . . .
Asia-Pacific
India, Japan to settle transfer pricing disputes under MAP
India and Japan are poised to resolve about 15 transfer pricing disputes under the mutual agreement procedure involving the automobile industry and large trading houses, writes Jayshree P Upadhyay of the Business Standard in a May 27 article. India also expects to soon resolve transfer pricing disputes involving the UK and France. See, Business Standard.
Multinational
OECD publishes comments on BEPS draft dealing with mandatory disclosure rules
The OECD on April 4 released public comments on a discussion draft under action 12 the base erosion profit shifting (BEPS) plan dealing with mandatory disclosure rules. The draft guidance, issued March 31, provides recommendations to tax administrations on how to structure mandatory disclosure rules . . .
FATCA/CRS
US IRS publishes updated FATCA IDES user guide, puts data preparation examples on Github
The US IRS on April 20 announced it has updated the FATCA International Data Exchange Service (IDES) user guide to include enhancements for reporting. . .
Featured News
OECD releases discussion draft on improving analysis of BEPS
The OECD on April 16 released a draft report under action 11 of the base erosion and profit shifting (BEPS) plan on improving the availability and analysis of data on BEPS and on monitoring the effectiveness and economic impact of actions taken to address BEPS. The report concludes that lack of data . . .
Multinational
Business reacts favorably to OECD draft on VAT for B2C supplies of services and intangibles
The OECD on February 24 released 47 comments to a discussion draft on OECD international VAT/GST guidelines relating to the place of taxation of business-to-consumer (B2C) supplies of services and intangibles. The draft, prepared under . . .
Americas
Canadian guidance addresses use of multiple year data in transfer pricing
The Canadian Revenue Agency (CRA) has issued guidance on the use of multiple year data in determining the arm’s length price in transfer pricing cases. The guidance also address the use of statistical tools . . .
Europe
Ireland releases guidance on qualifying avoidance disclosures
Irish Tax and Customs on January 30 released guidance on qualifying avoidance disclosures under Section 811A(2A) Taxes Consolidation Act 1997. Under the
. . .
Europe
UK and Monaco sign TIEA
The UK’s HMRC on January 28 published the text of a tax information exchange agreement (TIEA) signed recently by the UK and Monaco . . .
Americas
US and Qatar sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Qatar has signed a Model 1 intergovernmental agreement (IGA) with the United States as of January 7. The text of the agreement is available. See, agreement.
Europe
UK/Iceland treaty enters into force, text available
A tax treaty between the UK and Iceland, signed December 17, 2013, entered into force on November 10, the UK government announced December 15. See, text of UK/Iceland treaty.
Europe
Former PwC auditor charged in Lux Leaks theft
Former PwC auditor, Antoine Deltour, was charged with multiple crimes in Luxembourg on December 12 for stealing and leaking confidential PwC client advance tax rulings and other documents that were later placed on the Internet by the International Consortium of Investigative Journalists (ICIJ). He has admitted his involvement, but says that he did not provide all the material released on the ICIJ website. See, Blomberg, The Guardian, Luxemburger Wort, The Irish Times.
Americas
Ray Beeman joins EY
EY announced November 19 that Ray Beeman, former adviser to Chairman of the House Ways and Means Committee Dave Camp, has joined Ernst & Young’s National Tax Department in Washington, DC. As Tax Counsel and Special Adviser for Tax Reform, Beeman developed discussion drafts related to international tax, financial products, and pass-throughs. He also helped prepare The Tax Reform Act of 2014, released by Chairman Camp in February. See, EY release.
Europe
Germany and UK agree to modified nexus approach for IP regimes, existing arrangements grandfathered until 2021
Germany and the UK have agreed to a proposal that would put limits on preferential intellectual property regimes, including the UK’s patent box regime, for purposes of drafting uniform rules responding to Action 5 of the OECD/G-20 base erosion profit shifting (BEPS) plan. The compromise proposal breaks . . .
Africa
Ireland signs treaty with Ethiopia
Irish Tax and Customs has announced that Ireland signed a tax treaty with Ethiopia on November 3. The text of the treaty is not yet available. See, Irish Tax and Customs website.
Asia-Pacific
Philippines tax commissioner appointed to UN Committee of Experts
Bureau of Internal Revenue Commissioner Kim S. Jacinto-Henares has been appointed by UN Secretary General Ban Ki Moon as a member of the UN Committee of Experts on International Cooperation in Tax Matters in accordance with Economic and Social Council (ECOSOC) Resolution 2004/69, according to a November 4 press release.
Americas
US posts new FATCA Q&A on searching branch name and GIIN on FFI list
A new FAQ was posted on the US IRS’s FATCA website on October 27 in the Branch/Disregarded Entity category. The FAQ . . .
Europe
Richard Asquith joins Avalara
Richard Asquith has joined Avalara in the UK as VP of Global Tax Compliance, Avalara announced on October 21. Asquith was previously with the TMF Group. Release.
Africa
Hong Kong and South Africa sign double tax treaty – text available
Hong Kong and South Africa have signed an agreement for the avoidance of double taxation and . . .
Multinational
OECD publishes 28 comments on methods to collect and analyze BEPS data
The OECD on Oct. 7 published comments to Action 11 of its base erosion profits shifting (BEPS) initiative concerning the establishment of methodologies to collect and analyze data on BEPS and the actions to address it.
The OECD received 28 comments, including submissions from China and Costa Rica, prominent academics, trade associations, and advisers.
The comments were submitted in response to an August 4 OECD request for input.
Asia-Pacific
Dinesh Kanabar to leave KPMG India to launch his own firm
KPMG in India on Sept. 10 announced that Dinesh Kanabar will leave his post as Deputy CEO to start his own venture. Kanabar, a frequent speaker at international tax conferences, has been with KMPG for 4 years. release
Americas
Decision imminent on anti-inversion policy, says US Treasury official
The Obama administration will decide “in the very near future” whether it should exercise its regulatory authority to make corporate inversions less economically attractive, US Treasury Secretary Jacob Lew said on Sept. 8.
Speaking at the Urban Institute in Washington, Lew said that . . .
Asia-Pacific
China-Netherlands treaty to enter into force
China’s State Administration of Taxation has announced that a tax treaty and protocol signed by China and The Netherlands on May 31, 2013, will enter into force on August 31. Press release (Chinese).
Multinational
Asia-Pacific
Europe
UK Parliament hearing to focus on foreign takeovers of British Firms
The UK ‘s Economic Affairs Committee of the House of Lords, on July 8, will hold a hearing on foreign takeovers of British companies and the public interest. . .
Americas
US and Latvia sign Model 1 FATCA IGA
US Treasury Department has updated its FATCA website, reporting that Latvia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 27. Agreement
Asia-Pacific
Australia Inspector General of Taxation reports on ATO’s transfer pricing operations
Australia’s Inspector General of Taxation, Ali Noroozi, on June 2, released a comprehensive report on the Australian Taxation Office’s (ATO) management of transfer pricing matters. The document is dated December 2013. Report (PDF 2.9 MB)
Americas
Singapore/Barbados treaty enters into force
Singapore’s agreement with Barbados for the avoidance of double taxation entered into force on 25 April 2014. Release
Asia-Pacific
Germany and China sign tax treaty and protocol
China and Germany signed a new income tax treaty and protocol on March 28, according to a report by EY.
Americas
Europe
UK changes guidance on Dutch and Spanish VAT grouping rules under the ECJ’s Skandia ruling
The UK’s HMRC, in Customs Brief 23 issued December 11, updated its view of how UK businesses must account for VAT on intragroup supplies of services to branches that are part of VAT groups located in the Netherlands or Spain, following the European Court of Justice’s ruling in Skandia America . . .
Europe
UK publishes draft clauses for Finance Bill 2016 on hybrid mismatches, patent box, corporate transparency
The UK government on December 9 issued draft legislation for Finance Bill 2016, including measures addressing hybrid mismatch arrangements and the UK patent box, and introducing new transparency requirements for large corporations and partnerships. The government . . .
Americas
Americas
US IRS releases guidance to tax agents on intangible property licenses and deemed annual royalty income
The US IRS today released to the public two more international practice . . .
