Latest

Americas

US IRS large business/international unit adds new compliance campaign targeting cross-border activity

The US IRS’s Large Business and International (LB&I) division on November 4 announced . . .

Asia-Pacific

Switzerland’s Federal Council approves amendments to tax treaties with New Zealand, Netherlands, Norway, Sweden

Switzerland’s Federal Council on November 6 approved four tax treaty protocols . . .

Digital Economy

OECD-led global tax rewrite poised to ignore interests of small market, low-income countries, academics say: Allison Christians & Tarcisio Diniz Magalhaes→

OECD releases more guidance on implementing country-by-country reporting standards

November 5, 2019

The OECD today released additional guidance for tax administrations and multinational groups on the implementation and operation of country-by-country reporting. The . . .

Americas

US, Singapore negotiating exchange of country-by-country reporting data

November 4, 2019

The US Treasury on October 31 announced that the US and Singapore are . . .

Asia-Pacific

Cambodia parliament ratifies tax treaty with Hong Kong: Xinhua News→

November 4, 2019

What's New

Malaysia gives more tax perks to MNEs that establish headquarters there

Malaysia’s Ministry of International Trade and Industry, on October 6, announced enhancements . . .

Inclusive Framework on BEPS

OECD releases guidance for tax havens on exchanging information with other countries about shell corporation activity

The OECD today released guidance for low tax countries on standards for exchanging information . . .

Americas

Proposed regs would significantly restrict use of tax losses in US and international M&A transactions

Frank J. Vari, Practice Leader, at FJV Tax Consulting, Boston, Massachusetts, discusses recently released US proposed IRC §382 regulations which would dramatically reduce an acquiring corporation’s ability to use a target’s built-in losses, US net operating loss (NOL) carryforwards, and similar tax attributes following a substantial change in ownership . . .

Americas

Ukrainian Parliament ratifies FATCA agreement with US: 112 UA→

Americas

Brazil guidance addresses taxation of amounts paid under “cost-sharing” agreements

Francisco Lisboa Moreira, Tax Partner at Bocater Advogados, São Paulo, discusses important Brazil’s Federal Revenue Service guidance, issued October 2, on the tax treatment of amounts paid under a cost-sharing agreement between related group companies . . .

Europe

UK Labour Party may champion formulary apportionment, MP says: The Labour Party→

Europe

Multilateral tax treaty to enter into force for Latvia

The OECD announced on October 29 that Latvia has deposited its instrument . . .

Bosnia and Herzegovina

Bosnia and Herzegovina signs BEPS MLI on multinational group taxation

The OECD today announced that Bosnia and Herzegovina . . .

Europe

UK tax authority scrutiny of Airbnb intracompany transactions may lead to litigation, company says: James Graham / BBC News→

Digital Economy

Vestager says Europe should have its own digital tax if global agreement fails, praises countries that adopt unilateral measures: Laura Kayali, Simon Van Dorpe, & Thibault Larger / Politico→

Africa

EU Parliament approves public country-by-country reporting resolution

Members of the European Parliament on October 24 adopted a resolution urging . . .

Asia-Pacific

OECD’s latest MAP review includes focus on India

The OECD on October 24 released its sixth round of Stage 1 of peer review reports on base erosion and profit shifting (BEPS) action 14, assessing India, Argentina, Chile, Colombia, Croatia, Latvia, Lithuania, and South Africa, writes Prabhakar KS of Shree Tax Chambers, Bengaluru, India . . .

Europe

Jim Harra permanently appointed HMRC secretary and chief executive: Beckie Smith / Civil Service World→

October 29, 2019

Americas

US House passes bipartisan bill requiring companies to report ownership to federal government but exempts large or publicly traded companies: Steve Wamhoff / Fact Coalition→

October 29, 2019

Asia-Pacific

Turkey proposes 7.5 percent digital services tax on large multinationals

Ramazan Biçer a partner with Centrum, Istanbul, discusses in detail an October 23 draft digital services tax law introduced by Turkey’s Ministry of Treasury and Finance which would impose a 7.5 tax on the revenue of companies operating digital businesses Turkey . . .

Americas

US’s LB&I should change its approach to the selection of audit campaign issues, oversight agency says: Treasury Inspector General for Tax Administration→

Bulgaria

EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to Gibraltar companies from withholding tax

Davide Anghileri of the University of Lausanne, Switzerland, discusses a European Court of Justice Advocate General opinion concerning a Bulgarian law that excludes from the exemption from withholding taxes dividends paid by subsidiary companies incorporated in a Member State to their parent companies incorporated in Gibraltar . . .

Asia-Pacific

Jordan joins “Inclusive Framework on BEPS” to address taxation of multinational groups

The OECD today announced that Jordan has become . . .

Americas

BVI releases final rules on economic substance: British Virgin Islands International Tax Authority→

First Look: UN tax expert committee holds nineteenth session

The UN Committee of Experts on International Cooperation in Tax Matters held its nineteenth session at . . .

Africa

OECD’s Pillar One proposal could be first step toward shift in taxing rights to destination countries: Michael Devereux / University of Oxford→

Africa

Mauritius, Kenya tax treaty protocol signed

The Mauritius government has announced that a protocol . . .

Americas

US, Armenia FATCA agreement enters into force

US Treasury has announced on its website . . .

Africa

BEPS MLI to enter to force for Mauritius

Mauritius on October 18 deposited its instrument of ratification . . .

Asia-Pacific

Australia addresses implementation of rule requiring entities to align asset value for thin cap purposes with financial statement value: Australian Taxation Office→

Africa

Estimating reliable transfer pricing profit indicators requires use of all available data

Ednaldo Silva, Founder and Director at RoyaltyStat, writes that the arm’s length argument of many transfer pricing reports is weak because the sample is not random and the sample size of three-year data points is too small . . .

Europe

Ireland publishes tax guidance on tie-breaker rule for dual resident companies

Irish Tax and Customs on October 8 published new tax guidance which describes . . .

Digital Economy

Italy’s Council of Ministers make last-minute changes to draft of Budgetary Law 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland, writes about Italy’s Budget Plan 2020 and related measures, passed by the Council of Ministers with last-minute changes, which includes a digital services tax, environmental and sugar taxes, and measures to thwart tax evasion . . .

Europe

Ireland’s Finance Bill would update transfer pricing rules, adopt anti-hybrid tax provisions