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Latest

Canada

What the UK’s new transfer pricing and diverted profits tax statistics tell us

August 1, 2018

Liz Hughes, a partner with Grant Thornton UK LLP, discusses the UK’s 2017–18 transfer pricing and diverted profits tax statistics, released July 31, noting several interesting trends . . .

No Picture
Austria

Austria to seek consensus on digital tax during EU presidency: The Irish Times→

July 18, 2018
Americas

US IRS again delays foreign currency tax regs

June 13, 2018

The US IRS today announced that it will further extend the due date of section 987 final and temporary regulations dealing with the taxation of foreign currency gains and losses. The regulations were originally published . . .

No Picture
Americas

US can’t intervene in Apple’s European tax dispute, EU’s top court rules

May 21, 2018

The Court of Justice of the European Union (CJEU) has ruled that the United States may not intervene in the Apple state aid case, thus . . .

Europe

UK’s HMRC large business investigations yielded highest tax take ever last year: Out-law.com→ 

May 9, 2018
Europe

UK government seeks help drafting law to close “profit fragmentation” tax loophole

April 10, 2018

The UK government today opened a consultation on a proposal, announced in Autumn Budget 2017, to shut down tax avoidance schemes involving UK traders and professionals using a device called “profit fragmentation.” The government . . .

Asia-Pacific

Indian advance pricing agreement uses customs value as arm’s length price

March 30, 2018

Mumbai advisor Ajit Jain writes that India’s Central Board of Direct Taxes has recently entered into an advance pricing agreement where customs values was accepted as arm’s length price for transfer pricing purposes . . . .

Asia-Pacific

India hits the 200 APA milestone, signs first pact on advertising, promotional expense

March 5, 2018

Transfer pricing and tax litigator Ajit Jain discusses India’s recent progress signing advance pricing agreements with multinationals and notes that the first unilateral APA dealing with the controversial topic of advertisement marketing, and promotional expenses has been concluded . . . 

Europe

Dutch tax consolidation tax regime violates EU law, court rules

February 22, 2018

Jian-Cheng Ku and Tim Mulder of DLA Piper, Amsterdam, discuss the implications of a European Court of Justice (ECJ) decision released February 22 which concludes that the Dutch tax consolidation regime (fiscal unity) violates EU  law . . . 

Asia-Pacific

Israel weighs lowering 6% corporate tax rate to compete with US tax reform, Netanyahu says: Lilach Baumer / CTech→

February 19, 2018
Americas

Morgan Lewis nabs three more Baker McKenzie tax pros

February 5, 2018

Morgan Lewis today announced the expansion of its Chicago tax team, adding three new partners: Joshua Richardson, Adam Beckerink, and Michael Liu. Richardson, Beckerink, and Liu are formerly with Baker McKenzie. They join Tom Linguanti . . . 

Americas

Brazilian tax authority rules cross-border payment for software as a service (SaaS) subject to withholding

July 19, 2017

Brazilian attorneys, Francisco Lisboa Moreira and Carolina Silveira Becman of Castro, Barros, Sobral, Gomes, discuuss a Brazilian Federal Revenue Service’s opinion on the taxation of amounts paid, credited, used, delivered, or remitted abroad on the acquisition of access and remote use of software as a service (SaaS) . . .

Africa

Mauritius signs MLI to combat multinational tax avoidance

July 5, 2017

As expected, Mauritius today signed the the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). If ratified, Mauritius’ action . . .

Asia-Pacific

Israeli court uses flawed logic in key transfer pricing decision

June 29, 2017

Professor Rifat Azam, Radzyner School of Law, Herzliya discusses the Israeli District Court’s decision in Getko Ltd vs. Kfar Saba Assessing Officer, which strives to develop transfer pricing principles and guidelines in the Israeli tax law context . . .

Europe

Spain applies MLI to 86 tax treaties, opts for mandatory binding arbitration: EY→

June 15, 2017
No Picture
Europe

Switzerland’s revised VAT regime to enter into force in 2018

June 2, 2017

The partial revision of Switzerland’s Value Added Tax Act will come into force on 1 January 2018, writes Davide Anghileri of the University of Lausanne . . .

No Picture
Belgium

Belgium fairness tax system may violate EU law, court rules

May 18, 2017

Davide Anghileri of the University of Lausanne discusses a May 17 European Court of Justice decision finding that Belgium’s fairness tax system is incomparable with EU freedom of establishment concepts and the parent-subsidiary directive . . .

Americas

Trump proposes 15 percent corporate tax rate, territorial tax system

April 26, 2017

President Trump on Wednesday unveiled his tax plan, proposing steep reductions in both individual and corporate income tax rates as well as a move to a territorial tax . . .

Featured News

Italy clarifies patent box, R&D tax credit, business assets credit

March 19, 2017

Davide Anghileri of the University of Lausanne discusses tax guidance issued by the Italian Revenue Agency clarifying Italy’s patent box regime, the tax credit for research and development (R&D) activities, and the tax credit for new business assets. . . .

Asia-Pacific

Australian government introduces bill extending GST to imported low value goods→

February 27, 2017

See: Draft bill. See also: Draft Law Companion Guideline LCG 2017/D2.

Multinational

Countries imposing new nexus rules to tax nonresident enterprises, resetting source v. residence: Gary D. Sprague / Bloomberg BNA→

February 15, 2017

See: Bloomberg BNA.

Asia-Pacific

India stays operation of circular on taxation of indirect transfers of assets

January 17, 2017

India’s finance ministry on January 17 announced that it will suspend the operation of a circular issued last month concerning the taxation in India of indirect transfers of Indian assets through offshore . . .

Europe

France proposes diverted profits tax: EY→

November 26, 2016

See: EY.

Americas

Saudi Arabia FATCA IGA signed with US

November 16, 2016

The US Treasury Department has today updated its FATCA website, reporting that Saudi Arabia has signed a Model 1 intergovernmental agreement (IGA) with . . .  

Europe

MNEs can still use ‘double Irish’ loophole, lawmaker says: Irish Times→

November 10, 2016

See: The Irish Times.

Europe

Italy adds Switzerland to financial transactions tax white list

October 29, 2016

Davide Anghileri, a PhD researcher and lecturer at the University of Lausanne, discusses the implications of Italy’s decision to put Switzerland on its white list for purposes of the financial transactions tax . . .

Europe

New rules require businesses with large UK operations to publish tax strategy on internet

October 6, 2016

Sandy Bhogal and Kitty Swanson, of Mayer Brown, London, discuss the details of new UK rules that require large businesses to publish a tax strategy on the internet, noting several concerns with the provision . . .

Americas

Isle of Man signs tax information exchange agreement with Turks and Caicos Islands

September 20, 2016

The Isle of Man government has announced this week that it has signed a tax . . .

Americas

Jennifer Molnar rejoins Baker & McKenzie’s international tax practice

September 7, 2016

Jennifer Molnar has rejoined Baker & McKenzie as a partner in the firm’s Washington, DC office. Molnar advises on tax planning for international acquisitions . . .

Americas

New Mexican APA rules allow tax authority site visits: PWC→

August 7, 2016

See: PWC.

Americas

US IRS issues corrections to inversion regulations

June 23, 2016

The US IRS on June 23 issued corrections to final and temporary regulations (TD 9761) published April 8 dealing with inversions . . .

Americas

Panama, Bahrain, Lebanon, Nauru, Vanuatu pledge to combat tax evasion through automatic information exchange

May 11, 2016

Panama was among five countries that this week pledged to share financial account information automatically with other countries, the OECD . . .

Americas

US proposed regs would force shareholders of foreign owned-single member LLCs to reveal their identity, final regs require customer due diligence: White House→

May 6, 2016

See: White House, proposed regulations, press release, Letter by Treasury Secretary Lew.  More: Bloomberg, The Guardian, Wall Street Journal, Economic Times. 

Europe

Russian draft law introduces country-by-country reporting: EY→

April 21, 2016

See: EY.

Asia-Pacific

UAE, Finland sign tax information exchange agreement

March 29, 2016

The United Arab Emirates and Finland on March 27 signed an agreement on the exchange of information . . .

No Picture
Europe

Leaked EU directive for public country-by-country reporting allows aggregation of third country tax data

March 22, 2016

A proposed EU directive would require public country-by-country reporting by multinationals on worldwide operations broken down by EU member states, but disclosure of only aggregated data for non-EU operations, according to a leaked. . .

Americas

NGO effort to cast US MNEs as tax dodgers has succeeded, Stack says:  Alex M. Parker / Bloomberg BNA→

March 3, 2016

See: Bloomberg BNA.

Europe

Guernsey, Isle of Man, Jersey publish tax guidance on economic substance

May 7, 2019

The governments of Guernsey, Isle of Man, and Jersey on April 26 jointly published draft tax guidance on economic substance . . .

Americas

Mexico to tax digital platforms as interim measure, tax official says: Reuters→

April 9, 2019

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RECENT COMMENTS
  • 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

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • 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

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.