Latest – Page 63 of 157

Europe

Switzerland, Ireland sign protocol amending tax treaty

June 13, 2019

Switzerland and Ireland today signed a protocol to their tax treaty adding . . .

Americas

Argentina modifies transfer pricing regime

May 29, 2019

Sandra Diaz, a partner with Basa Firma, discusses changes to Argentina’s transfer pricing requirements published on May 27 . . .

Asia-Pacific

Japan, Finland to negotiate tax treaty amendments

May 21, 2019

The governments of Japan and Finland will . . .

Switzerland, South Korea sign tax treaty protocol

May 17, 2019

Switzerland and South Korea today signed a protocol to their 1980 tax treaty adding . . .

Americas

US IRS releases final foreign currency regulations

May 14, 2019

The US IRS on May 13 published final tax regulations applicable to multinationals . . .

Asia-Pacific

New Zealand’s revised transfer pricing regime

May 13, 2019

Leslie Prescott-Haar, Stefan Sunde, and Sophie Day of TP EQuilibrium | AustralAsia LP, discuss final international tax and transfer pricing guidance published by the New Zealand Inland Revenue April 29 . . .

Europe

Italy amends patent box regime, adopts other tax reforms

May 9, 2019

Davide Anghileri of the University of Lausanne discusses a new package of Italian tax measures which include amendments to Italy’s patent box regime and an asset basis step-up on certain mergers, division, or contributions . . .

Cyprus

Cyprus Finance Minister drops proposal to increase corporate tax rate from 12.5 to 15 percent following business outcry: Bouli Hadjioannou / in-Cyprus→

August 7, 2019

Europe

EU Commission says Greece must allow deductions for foreign losses

July 30, 2019

The EU Commission has charged that Greece’s tax treatment of losses incurred . . .

Asia-Pacific

Synthesized text of Japan-UAE tax treaty published showing MLI modifications

July 20, 2019

The Japanese government on July 1 published the . . .

Africa

OECD seeks input on tax dispute resolution in Andorra, Anguilla, Bahamas, Bermuda, BVI, Cayman, Faroe Islands, Macau, Morocco, Tunisia

July 17, 2019

The OECD on July 5 requested taxpayer feedback on the tax treaty dispute . . .

Asia-Pacific

Hong Kong, Cambodia sign tax treaty

June 26, 2019

Hong Kong and Cambodia today signed . . .

Asia-Pacific

Malaysian prime minister advocates e-commerce tax on online business: Danisha Hakeem / The Online Citizen→

June 24, 2019

Europe

EU court rules on deductibility of losses of sub-subsidiary, losses transferred through merger

June 24, 2019

Davide Anghileri of the University of Lausanne discusses two ECJ decisions released June 19 addressing when EU States are required by EU law to allow a parent company to deduct in Sweden final losses of a group member; one case involved losses of a sub-subsidiary located in Spain and the other of a Germany subsidiary later merged into its Swedish parent . . .

Africa

First Look: South Africa publishes draft taxation laws

June 18, 2019

The South African government today published portions of the draft Taxation . . .

Digital Economy

UN tax committee releases report on discussion and conclusions reached at eighteenth session: United Nations→

June 17, 2019

More News

OECD study suggests automatic exchange of information reduced bank deposits in offshore financial centers

June 7, 2019

Preliminary findings of an upcoming OECD study show that automatic exchange of information has reduced cross-border bank deposits in 46 international . . .

French court reaches surprising conclusions on cost plus transfer pricing method

June 6, 2019

Terence Wilhelm of Cara Avocats, France, discusses a French case, Labs France, where the court addressed the treatment of taxes for purposes of the cost plus transfer pricing method . . .

OECD publishes work plan for sweeping international tax reform

May 31, 2019

As expected, the OECD today published a work plan setting out a process for reaching global consensus on revised rules for taxing multinationals. This key document had been agreed to by the 129-country . . .

Asia-Pacific

Synthesized text of Australia-Singapore tax treaty published: Australian Taxation Office→

May 25, 2019

Europe

Shell reveals that only one of its subsidiaries paid tax in Netherlands where the group is headquartered, prompting calls for tax avoidance hearing: Reuters→

May 21, 2019

Americas

France should renegotiate FATCA unless US agrees to concessions aiding dual nationals, parliamentary report says: Gregory Viscusi / Bloomberg→

May 16, 2019

Europe

Ireland should “engage constructively” on digitalization, tax avoidance to safeguard reputation, IMF says: International Monetary Fund→

May 14, 2019

Digital Economy

EU leaders to discuss tax priorities at summit

May 8, 2019

The EU Commission has prepared a paper in advance of a May 9 EU leaders meeting which . . .

Americas

Peru clarifies general anti-avoidance rule for cross-border transactions

May 8, 2019

Franz Salazar Anccasi of TPC Group, Peru, discusses important changes to Peru’s general anti-avoidance rule published on May 6 . . .

Americas

US proposed regs address withholding, reporting for partnerships with foreign partners

May 8, 2019

The US IRS on May 7 published proposed tax regulations (REG-105476-18) applicable to . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Europe

Ireland Budget 2019 announces new taxes on assets shifted offshore

October 9, 2018

As a part of Ireland’s commitment to implement the EU Anti-Tax Avoidance Directive, Ireland’s Finance Bill will provide for new exit tax . . .

Europe

Proposed changes to Ireland’s transfer pricing regime could affect UK interest-free lending structures: KPMG→

September 24, 2018

Americas

Canada speeding up completion time for advance pricing agreements, report shows

August 6, 2018

Kabir Jamal of Goodmans LLP, Toronto, discusses Canada’s 2017 advance pricing agreement report, which reveals improvements in the operation of this government program designed to provide multinational taxpayers with certainty regarding their prospective transfer pricing transactions . . .

OECD discussion draft on transfer pricing for financial transactions avoids key issues

July 19, 2018

Julian Feiner of Dentons, London, analyzes the OECD’s July 3 discussion draft on the transfer pricing aspects of financial transactions, highlighting three issues that warrant further consideration …

Asia-Pacific

Australia issues final tax guidance on central management and control test for foreign companies

June 27, 2018

The Australian Taxation Office has issued final taxation guidance setting out how the . . .

Europe

Russian customs proposes to impose duty on all imports of goods sold by foreign online stores by 2020: Crime Russia→

June 18, 2018

EU puts public country-by-country reporting of tax data back on the agenda

June 14, 2018

After several quiet months, it seems that consideration of an EU Commission proposal for public country-by-country reporting is now moving forward . . .

Europe

Germany suspends interest charge on late tax payments providing relief for MNEs

May 16, 2018

Ninja-Antonia Reggelin discusses the German Federal Fiscal Court’s May 14 announcement that it will suspend a law imposing large interest charges on unpaid taxes because the law may be unconstitutional . ..

Asia-Pacific

Macau ready to sign OECD agreement to allow automatic tax information exchange: Nelson Moura / Macau News Agency→

May 7, 2018

Switzerland focusing on resolving disagreements over Tax Proposal 2017, which will likely be resolved, after that, attention will turn to taxation of digital economy, Oberson says: CNN Money Switzerland

April 20, 2018

Americas

IRS guidance addresses new tax law’s limits on business interest deductions

April 2, 2018

The US IRS today issued guidance on the new cap on large businesses’ interest deductions, enacted in the Tax Cuts and Jobs Act in December 2017. The new rules . . .

Americas

Dominican Republic tax authorities requesting documentation to verify transfer pricing, loans: KPMG→

March 19, 2018

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