India’s government will propose tax law amendments that clarify that foreign institutional and portfolio investors (FIIs/FPIs) are not subject to the minimum alternate tax (MAT) on their pre-April 1 income, Finance Minister Arun Jaitley told a news conference . . .
The OECD on July 7 released a model protocol to tax information exchange agreements to be used by governments wishing to extend . . .
US Senate Finance Committee Chairman Orrin Hatch (R-Utah) in a July 16 letter requested that the US Government Accountability Office (GAO) conduct an analysis of the impact of the OECD/G20 base erosion profit shifting project (BEPS) on American . . .
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
The UK’s HM Revenue and Customs on May 21 issued guidance on the treatment of holding companies and treasury companies under FATCA, the multilateral competent authority agreement implementing the common reporting standard, and the . . .
A high level committee constituted by India’s finance ministry has invited taxpayers, associations, and other stakeholders to set up meetings with the committee to discuss ways to clarify India’s tax laws. The . . .
Irish Tax and Customs, on April 16th, released guidance on the tax treatment of investments in exchange traded funds. According to a government . . .
Portugal, on March 5, ratified at tax treaty Georgia, signed December 12, 2012. An English-language version of the treaty is available
. . .
Government and OECD tax officials at a February 17 OECD hearing suggested that, contrary to business representative assertions, a 30 percent of EBITDA fixed ratio is too high to effectively combat excessive multinational corporation interest deductions. Officials suggested that a lower percentage is appropriate for guidance on interest deductions being drafted under the OECD/G-20 base erosion and profit shifting (BEPS) plan. The day-long hearing concerned draft BEPS guidance under action 4, released December 18, that would limit . . .
The United Arab Emirates will complete and sign a Model 1 FATCA IGA this month and will send the agreement electronically to the US IRS in September 2015, UAE HE Younis Haji Al Khoori, Undersecretary of the Ministry of Finance told reporters February 15. The UAE had reached an agreement . . .
The Irish government on January 29 released guidance clarifying a law added in the Finance Act 2013 that provides for an additional foreign tax credit for foreign dividends received . . .
An advance pricing agreement (APA) issued to Amazon by the Luxembourg tax authorities setting the price of intra-group royalties seems to be designed to ensure a predictable level of profit to Amazon’s Luxembourg operations rather than to achieve an arm’s length result, and thus appears likely to be state aid, the European Commission . . .
Taiwan’s tax authority, in an English-language release issued January 8, provided a brief description of transfer pricing disclosure and documentation requirements that must be met by profit-seeking enterprises when filing their annual income tax return. See, release.
Singapore and the US on December 9 signed a FATCA Model 1 Intergovernmental Agreement (IGA), following the initialing of the agreement May 5, the Inland Revenue Authority of Singapore has announced. The IGA is designed to simplify FATCA information reporting for Singapore financial institutions. See, Singapore release.
Russian President Vladimir Putin on December 1 signed addendums to the country’s tax code providing enhanced tax benefits to residents of the free economic zone in Crimea, Russian news agency TASS has reported. Under the new provisions . . .
Jersey and Romania on December 1 signed a tax information exchange agreement (TIEA) at the Romanian Embassy in London, the government of Jersey has . . .
The Australian tax office (ATO) has revoked six advance pricing agreements (APAs) with multinationals within the last six months because the government had been misled and the companies were engaging in aggressive tax planning, reports Nassim Khadem of the Brisbane Times in a November 7 report, quoting ATO deputy commissioner, Mark Konza. Konza also said the ATO is reviewing the activities of 80 high risk multinationals. See, Brisbane Times.
The US IRS on October 15 posted a “recent development” to the TY2014 Instructions for Form 1042-S, as follows:
“The 2014 Form 1042-S posted to IRS.gov on 04/02/2014 supersedes the 2014 Form 1042-S posted to IRS.gov on 03/12/2014. We are re-posting this form to correct the formatting of the recipient’s address in order to facilitate the mailing of this form to taxpayers.” See, FATCA website.
The European Commission has concluded that a Spanish tax scheme benefiting companies that acquire foreign shareholdings is incompatible with EU state aid rules . . .
Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced.
Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .
OECD and G20 country tax officials have agreed that minimum standards should be added to tax treaties to prevent treaty shopping; have decided on the content required for transfer pricing documentation, including country-by-country reporting; and have narrowed the scope of hybrid mismatch proposals, OECD officials said during a Sept 16 OECD webinar introducing the first seven OECD base erosion profit shifting (BEPS) deliverables.
The OECD guidance, released as part of . . .
The requirements for the entry into force of the treaty between Luxembourg and the Czech Republic, signed March 5, 2013, were met on July 31 and the treaty entered into force as of that date, the Luxembourg tax authority has announced. Release (in French), A Memorial – No. 162 of August 14, page A 2501 (in French)
The OECD, on Sept. 1, released a condensed version of the 2014 Model Tax Convention on Income and Capital.
The document includes the text of the articles of the Model as they read on July 15, 2014, after the ninth update by the Council of the OECD. Also included is an introduction, commentaries to the articles, and the positions of non-member countries. 2014 Model Tax Convention, prior coverage
The Qatar Financial Centre Authority has released an updated version of the Qatar financial centre (QFC) tax regulations, writes EY, in an August 11 report. For an analysis of the new regulations, see, EY.
Albania’s Ministry of Finance has issued guidance on new Albanian transfer pricing laws which became effective in June, according to a July 25 report by EY. For a detailed discussion of the new guidance, see EY.
South African Minister of Finance, Mr Nhlanhla Nene, and U.S. Ambassador to South Africa, Mr Patrick H. Gaspard, on June 9, signed an intergovernmental agreement to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA). Release
US firm, Illinois Tool Works Inc, has petitioned Tax Court to challenge the IRS’s decision to recharacterize a loan from its Bermuda subsidiary to a US affiliate as a taxable repatriation of profits, writes Patrick Temple-West, Reuters.
Ireland’s Department of Finance, on May 27, announced a consultation to consider international stakeholder’s views on how Ireland’s tax system should respond to the OECD’s base erosion and profit shifting (BEPS) initiative.
“Ireland remains 100% committed to the 12.5% corporation tax rate.
See also, Why Ireland should address corporate tax residency rules before we’re forced to, By Feargal O’Rourke, The Irish Times
Inland Revenue of Singapore, on May 19, released a tax guide for issuers, investors, and potential investors of hybrid instruments. The guide lists the factors the Comptroller of Income Tax (CIT) considers to determine if an instrument is classified as debt or equity and describes the income tax treatment of such instruments. The guide also clarifies that an advance ruling can be obtained from the CIT on the tax treatment of a hybrid instrument. IRAS e-Tax Guide
Canada’s Federal Court of Appeals has affirmed the Tax Court’s ruling, in Canada v. Lehigh Cement Limited, that a taxpayer’s acquisition of shares in a a non-resident company did not result in avoidance of tax. In so doing . . .
The Australian Taxation Office, on April 17, released four documents providing guidance on the transfer pricing laws . . .
The OECD has released a discussion draft on transfer pricing documentation and country-by-country reporting in response to action item 13 of the base erosion and profit shifting (BEPS) plan. Action 13 calls for a review of the existing transfer pricing documentation . . .
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