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New Zealand ratifies BEPS MLI

August 2, 2018

New Zealand has ratified the BEPS multilateral instrument (MLI) the New Zealand government today announced. The treaty, formally . . .

Africa

South Africa publishes draft tax bills

July 18, 2018

South Africa’s National Treasury on July 17 published the 2018 Draft Taxation Laws Amendment Bill and 2018 Draft Tax Administration Laws Amendment Bill for public comment. The proposed . . .

MEP asks EU Commission to investigate whether Shell/Netherlands merger deal avoiding dividend tax was EU State aid: DutchNews.nl→

June 18, 2018

Europe

Finland to terminate tax treaty with Portugal, government warns

June 13, 2018

Finland’s government will notify Portugal on June 14 that it will terminate the 1970 . . .

Countries make headway on country-by-country reporting

May 25, 2018

An OECD report released May 24 found that 60 out of 95 countries reviewed have adopted final legislation to require multinationals to file country-by-country reports consistent with . . .

Asia-Pacific

Pakistan’s Senate rejects government proposal to tax revenue from online activities including digital advertising: Mehtab Haider / The News→

May 7, 2018

Americas

China to immediately impose tariffs on 128 US products: Damian Paletta / The Washington Post→

April 2, 2018

Asia-Pacific

Singapore tax officials again consider making private tax rulings public

March 19, 2018

The Inland Revenue Service of Singapore today announced it is seeking public feedback on whether advance tax rulings should be made public while protecting . . .

Americas

US IRS releases frequently-asked-questions on new tax law’s deemed repatriation of foreign earnings

March 13, 2018

The US IRS today released frequently-asked-questions designed to help taxpayers meet the filing and payment obligations of the section 965 transition . . ,

Europe

Italy issues draft tax regulations on arm’s length standard, corresponding adjustments

February 22, 2018

Italy’s Ministry of Economy and Finance on February 21 released for public consultation draft regulations designed to align Italy’s transfer pricing rules with the outcome of Actions 8–10 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, writes Davide Anghileri, University of Lausanne . . .

Americas

Goodbye to All That?: A Requiem for the Destination-Based Cash Flow Tax: Daniel Shaviro / SSRN→

February 19, 2018

Europe

Amazon settles French tax dispute over income allocation for undisclosed sum: Reuters→

February 5, 2018

Americas

Brazilian guidance addresses taxation of cross-border software licensing payments

May 7, 2019

Francisco Lisboa Moreira, a partner with Bocater, Camargo, Costa e Silva, Rodrigues Advogados, discusses the Brazilian Federal Revenue’s April 15 guidance addressing the taxation of cross-border software licensing for commercialization or distribution . . .

Asia-Pacific

India, Netherlands negotiating tax treaty amendment to plug share transfer loophole: Gireesh Chandra Prasad / LiveMint→

April 10, 2019

Europe

Intragroup IP transfer was undervalued for tax purposes, Norway appeals court rules

April 2, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss an interesting March 19 Norwegian appellate court decision which concluded that the “relief from royalty” valuation method should not have been used to determine the value of an intangibles transfer in a merger and acquisition transaction involving Dynamic Rock Support AS . . .

Americas

India, US sign agreement for exchange of country-by-country reports: Hindu Business Line→

March 27, 2019

Americas

France’s new digital tax could spur US countermeasures, lawmaker says: Kevin Brady / US House of Representatives→

March 6, 2019

Asia-Pacific

New Zealand to explore digital services tax for multinationals

February 19, 2019

The New Zealand government today announced that it will open . . .

Asia-Pacific

Dyson to move its headquarters from UK to Singapore, claims tax reduction will be “negligible”: Michael Pooler & Jim Pickard / Financial Times→

January 22, 2019

Europe

Irish tax take unexpectedly surges 20 percent as multinationals transfer assets there: Eoin Burke-Kennedy & Pat Leahy / New Irish Times→

December 10, 2018

The Government is on course to run a budget . . .

More: New York Times,

Digital Economy

UK seeks feedback on design of new digital services tax

November 8, 2018

The UK today launched a consultation seeking feedback on the design of its . .

Europe

Ukraine publishes draft tax and transfer pricing law to implement BEPS provisions

October 29, 2018

Ukraine’s Ministry of Finance and the National Bank of Ukraine have published a draft amendment to the tax code designed to implement international tax and transfer pricing provisions . . .

Africa

IMF paper concludes African countries worse off for signing tax treaties with “investment hubs” like Mauritius

October 26, 2018

African countries that signed tax treaties with Mauritius and other nations considered to be “investment hubs” did . . .

Asia-Pacific

New Zealand proposal would impose GST on foreign online low-value sales

October 17, 2018

New Zealand’s Minister of Revenue today announced proposed new GST rules applicable to online . . .

Asia-Pacific

Saudi Arabia publishes English-language VAT guides

October 5, 2018

The Saudi Arabia tax authority has published English-language versions of four . . .

Americas

US IRS proposes to withdraw controversial Section 385 debt-equity documentation regulations

September 23, 2018

The US IRS on September 21 proposed to revoke the hotly contested Section 385 debt-equity documentation regulations and work toward developing . . .

Americas

OECD, EU require Barbados to remove ring-fenced international tax regimes by December 31, Prime Minister says: Katrina King / Barbados Today→

August 27, 2018

Asia-Pacific

Australian Taxation Office to focus on migration of IP offshore, official says: Nassim Khadem / The Sydney Morning Herald→

July 18, 2018

Asia-Pacific

New Zealand passes BEPS bill to prevent multinational tax avoidance

June 27, 2018

New Zealand’s parliament has passed the Taxation (Neutralising Base Erosion and Profit Shifting) Bill, aimed at curtailing tax avoidance by multinationals, Revenue Minister . . .

Austria

Kerim Keser joins Duff & Phelps’ European transfer pricing practice

June 13, 2018

Kerim Keser is the new head of Duff & Phelps’ German, Swiss, and Austrian transfer pricing practice, the firm announced . . .

Africa

South Africa releases guide on resolving cross-border tax disputes

May 23, 2018

The South African Revenue Service (SARS) has produced a draft guide on the mutual agreement procedure(MAP) which allows the . . .

Digital Economy

UN won’t wait for OECD action to tackle digital economy taxation

May 21, 2018

The UN Committee of Experts on International Cooperation in Tax Matters will not wait for the OECD to reach final conclusions on the taxation . . .

Americas

UK reverses support for EU interim digital tax fearing US retaliation, sources say: Bjarke Smith-Meyer / Politico→

April 29, 2018

Americas

IRS signed 116 advance pricing agreements in 2017

March 30, 2018

The US IRS today released statistics on the performance of its advance pricing agreement (APA) program in 2017, revealing that the tax agency signed 116 APAs that year. APA are agreements signed between the tax agency and multinational taxpayer resolving transfer pricing . .

Europe

Netherlands reveals plan for new withholding tax regime, increased substance requirements

March 5, 2018

Jian-Cheng Ku and Tim Mulder of DLA Piper, Amsterdam, discuss new Dutch government proposals for a conditional withholding tax on royalties, interest, and dividends and increased substance requirements for Dutch holding, license, and financing companies . . .

Americas

Cayman Islands issues notice on country-by-country reporting for multinationals

February 9, 2018

The Cayman Island government on February 2 published an advisory for multinational corporations on country-by-country reporting in advance of the release of planned guidance on the topic. The government . . .

Asia-Pacific

Israel planning tax changes in response to US reform, seeks updated US tax treaty, considers digital firm taxation: Shoshanna Solomonnad / The Times of Israel→

February 5, 2018

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UN publishes tax committee working methods and practices

May 7, 2019

The UN today published a document outlining the practices and working methods . . .

Asia-Pacific

Australia consults on gas transfer pricing arrangements, submissions due June 14: Australian Treasury→

April 10, 2019

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