Latest – Page 59 of 157

Americas

Altera files Ninth Circuit petition for rehearing in challenge to US cost-sharing regulations: Steve Dixon / Miller & Chevalier→

July 25, 2019

Multinational

Each purchase with Facebook’s proposed digital currency, Libra, would require immediate realization of taxable gain/loss: Chris Giles / Financial Times→

July 1, 2019

Morocco signs multilateral agreement on exchange of country-by-country reports

June 25, 2019

Morocco has signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports, becoming . . .

Europe

Spanish appeals court rules on IKEA subsidiary’s approach to transfer pricing comparability, arm’s length range

June 24, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss the Spanish Court of Appeal’s decision earlier this year in IKEA, a transfer pricing case addressing the taxpayer’s application of the transactional net margin method (TNMM) . . .

Americas

House Ways and Means lawmakers urge US response to France’s digital tax proposal

June 20, 2019

US House Ways and Means Committee members . . .

Digital Economy

On turnover-based taxes and digital taxes: the EU Advocate General’s opinion in Vodafone

June 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses an EU Advocate General’s opinion issued June 13 addressing Vodafone’s challenge to the Hungarian telecommunication tax . . .

Americas

US-Dominican Republic FATCA agreement enters into force

July 25, 2019

The US Treasury has announced on its website that the US-Dominican Republic Model 1 FATCA intergovernmental . . .

More News

Baker McKenzie appoints transfer pricing expert as new global head of tax

July 20, 2019

Baker McKenzie has appointed . . .

Asia-Pacific

Turkey proposes another tax amnesty for repatriation of foreign assets

July 17, 2019

Ramazan Biçer of Centrum Turkey discusses the Turkish government’s latest tax amnesty, proposed on July 8, which applies to the repatriation of foreign assets . . .

Americas

US announces probe into France’s digital services tax

July 10, 2019

The US will investigate whether France’s digital services tax, expected to pass the Senate . . .

Europe

Netherlands draft tax law targeting hybrid mismatches includes new documentation requirement

July 7, 2019

Mehdi el Manouzi and Michiel Moison of PwC Netherlands discuss the Dutch government’s July 2 legislative proposal implementing the EU rules targeting hybrid mismatches . . .

Europe

EU directive on tax dispute resolution enters into force

July 1, 2019

New rules aimed at resolving cross-border tax disputes . . .

Europe

Guernsey proposes amendments to economic substance, tax residency rules

June 20, 2019

The Guernsey Revenue Service on June 17 announced proposed changes to the economic substance regulations for tax residency. The . . .

Europe

UK tribunal reverses controversial decision on Jersey companies’ tax residency under central management and control test

June 13, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss an important UK tribunal decision addressing the central management and control test for tax residency . . .

Europe

UK opens consultation on insurance premium tax avoidance, fee manipulation: Matt Sheehan / Reinsurance News→

June 6, 2019

Asia-Pacific

China extends temporary tax break for integrated circuit and software industry: EY→

May 30, 2019

Africa

Switzerland’s Federal Council approves plan to exchange account data with 19 more country tax administration

May 30, 2019

Davide Anghileri of the University of Lausanne writes that Switzerland’s Federal Council adopted a dispatch yesterday approving the introduction of automatic exchange of financial account information with 19 more countries . . .

Asia-Pacific

Singapore tax guide addresses transfer pricing for commodity marketing, trading

May 28, 2019

Singapore’s Inland Revenue Service on May 24 released a new E-Tax guide aimed at helping . . .

Austria

EU loss in Polish State aid case may be a win for digital services tax

May 17, 2019

Leopoldo Parada of the University of Turin, Italy, discusses a May 16 EU General Court decision in Poland v. Commission which could have implications for the legality, under EU State aid rules, of unilateral European digital services tax measures . . . .

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Americas

US MNEs reversing inversions, less likely to invert in the first place, because of 2017 tax changes: Richard Rubin & Jared S. Hopkins / WSJ→

August 1, 2019

Americas

IRS issues final partnership regs on allocation of creditable foreign taxes

July 25, 2019

The US IRS on July 24 published final regulations . . .

Asia-Pacific

New South Korea tax chief promises to reduce investigations into company tax affairs: Yonhap News Agency→

July 2, 2019

G20 leaders approve digital work plan to address taxation of multinational groups

July 1, 2019

G20 leaders, at their summit in Osaka, Japan on June 28–29 endorsed a work plan developed by. . .

Americas

US Senate Foreign Relations Committee approves tax treaty protocols with Japan, Luxembourg, Spain, Switzerland

June 25, 2019

Tax treaty protocols amending US tax treaties with Japan, Luxembourg . . .

Europe

Dutch government to promote EU-wide carbon pricing, aviation taxes at two-day conference: Netherlands government→

June 20, 2019

American Samoa

Dominica removed from the EU tax blacklist

June 17, 2019

The Council of the EU on June 14 removed Dominica from the . . .

Americas

Newly signed Brazil-Uruguay tax treaty will force companies to review structures

June 13, 2019

Francisco Lisboa Moreira of Bocater, Camargo, Costa e Silva, Rodrigues Advogados discusses the new Brazil–Uruguay tax treaty and protocol, signed June 7 . . .

Europe

Malta publishes new rules for consolidated groups: Government Gazette of Malta→

June 10, 2019

Europe

Italy clarifies interaction of patent box regime and foreign tax credit

June 10, 2019

Davide Anghileri of the University of Lausanne discusses clarifications made by the Italian revenue agency on May 28 concerning the interaction of the Italian patent box regime the foreign tax credit. . .

Americas

US urging market countries to accept only modest changes to international tax system

June 6, 2019

The US is urging countries to agree to new international tax rules that would allocate a limited amount of additional profit and related taxing rights to countries where a multinational’s customers or digital users reside. In exchange for these additional taxing . . .

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

May 29, 2019

Americas

US IRS publishes final section 956 regs applicable to US corporate shareholders

May 23, 2019

The US IRS today published final regulations that provide a mechanism to exclude corporations . . .

American Samoa

EU Council revises tax blacklist, plans less frequent list updates

May 17, 2019

Davide Anghileri of the University of Lausanne discusses today’s decisions by the EU Council regarding the EU list of non-cooperative tax jurisdictions . . .

Europe

Multilateral tax treaty to enter into force for Norway

July 29, 2019

The OECD today announced that Norway has deposited its instrument . . .

Asia-Pacific

Australian taxation office explains hybrid mismatches through structured arrangements

July 25, 2019

The Australian Taxation Office (ATO) on July 25 issued new guidance on the meaning of . . .

Asia-Pacific

Amended India-China tax treaty protocol enters into force

July 19, 2019

An amending protocol to the China-India tax treaty has entered into force according to a July 17 notice of the Indian government, writes Prabhakar KS of Shree Tax Chambers . . .

Europe

UK Finance Bill 2019-20: what international businesses need to know

July 17, 2019

David Hughes and Helena Kanczula of Blick Rothenberg Limited, London, discuss selected provisions in draft legislation and explanatory notes to the UK Finance Bill 2019-20 published on July 11 including the UK’s proposed digital services tax . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin