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Latest

Americas

Ecuador adds Hong Kong to tax haven blacklist: EY→

August 28, 2017
Americas

Miesel to lead Mazars’s US transfer pricing practice

August 15, 2017

Victor H. Miesel has joined Mazars USA as a partner, national transfer pricing practice leader, and chief economist, Mazars announced . . .

Americas

Argentina suspends new rules for taxing nonresident capital gains: KPMG→

August 3, 2017
Europe

Bortolotti to join Dentons Luxembourg as a transfer pricing partner

July 19, 2017

Dentons today announced that Cristiano Bortolotti will join the firm as a transfer pricing partner in the firm’s Luxembourg office. Bortolotti will also develop and assist more broadly the tax practice . . .

Americas

US to repeal or revise debt-equity regulations, other tax guidance, under Trump order

July 9, 2017

US Treasury has identified eight tax regulations — including the section 385 debt-equity regulations, the section 367 regulations affecting foreign goodwill and going concern value, and the section 987 foreign currency regulations — as qualifying for revision under President Trump’s executive order mandating a reduction in . . .

G20

OECD reports to G20 leaders on status of international tax agenda, tax transparency: OECD Secretary-General→

July 5, 2017
Asia-Pacific

UK and Australia’s different PE profit attribution approach yields double taxation and nontaxation: Celeste Black / SSRN→

June 28, 2017
Cyprus

Luxembourg, Cyprus tax treaty published

June 8, 2017

Luxembourg’s tax administration has released on its website the text of a tax treaty and protocol signed by the Luxembourg. . .

Asia-Pacific

McDonald’s could run afoul of Australia’s diverted profits tax: Nassim Khadem / The Sydney Morning Herald→

June 1, 2017
Cyprus

Luxembourg, Cyprus sign tax treaty

May 8, 2017

Luxembourg and Cyprus have signed a tax treaty, Luxembourg’s Ministry of Finance announced today. The agreement. . .

Americas

Trump won’t back border adjustment tax, sources say: Kate Kelly, Rachel Abrams, Alan Rappeport: The New York Times→

April 25, 2017
Europe

UK updates GAAR guidance: HM Revenue & Customs→

April 7, 2017
Americas

Kautter to be appointed US assistant secretary for tax policy, sources say

April 4, 2017

The Trump administration has selected David Kautter as the next US assistant secretary for tax policy, a post critical for moving forward the US tax reform agenda, Poltico has Poltico has reported. Kautter, a partner and leader . . .

Americas

US, ​Saudi Arabia FATCA agreement enters into force

March 29, 2017

The US Treasury Department has updated its FATCA website, reporting that a Model 1 intergovernmental. . .

Featured News

The lack of transfer pricing comparables: selecting the appropriate box of apples in which to find bananas

March 16, 2017

Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .

Africa

 Jersey, Mauritius sign tax treaty

March 3, 2017

A tax treaty was signed by Jersey and Mauritius government officials today, according to a government of Jersey . . .

Asia-Pacific

India, Austria tax treaty protocol signed

February 7, 2017

Indian and Austrian government officials on February 6 signed a protocol to their 1999 tax treaty that would broaden the scope of the countries’ existing framework of exchange of tax. . . .

Europe

Netherlands tax director steps down

January 17, 2017

The Netherlands’ Director of General Tax Administration, Dr. JAJ (Hans) Leijtens, has resigned his post, the Netherlands government
. . .

Americas

British Virgin Islands set to join OECD Inclusive Framework on BEPS

December 19, 2016

The British Virgin Islands will join the OECD/G20 Inclusive Framework, pledging to adopt and work toward the implementation of the minimum international tax standards in the OECD/G20 Base Erosion Profit Shifting . . . 

Europe

Luxembourg transfer pricing bill would adopt some BEPS changes

October 28, 2016

Dr. Paloma Schwarz Martínez, University of Luxembourg, discusses a new bill under consideration by Parliament that would incorporate some of the BEPS transfer pricing changes into Luxembourg law . . . 

No Picture
Europe

EU Commission publishes decision to extend Gibraltar state aid probe to tax rulings

October 6, 2016

The European Commission has published a non confidential version of its decision to open an investigation into whether Gibraltar’s tax ruling practice violates . . . 

Americas

Isle of Man tax information exchange agreements with BVI, Cayman Islands, and Romania enter into force

September 20, 2016

The Isle of Man government announced this week that three tax information exchange agreements signed with other nations. . .

Asia-Pacific

Singapore appoints new Inland Revenue Authority board

September 7, 2016

Singapore has announced the make up of the members of the Board of Inland Revenue Authority of Singapore (IRAS), effective . . .

Americas

Kadet & Koontz offer objective ethical framework to test MNE profit shifting structures: SSRN→

August 7, 2016

See: Profit-Shifting Structures: Making Ethical Judgments Objectively, by Jeffery M. Kadet, David L. Koontz, SSRN. Part one, Part two.

Europe

Petteri Orpo takes over as Finland’s Minister of Finance

June 28, 2016

Finland’s President on June 22 appointed Petteri Orpo as Minister of Finance . . .

Multinational

OECD appoints EY’s VanderWolk to lead tax treaties, transfer pricing, financial transactions division

June 2, 2016

The OECD on June 2 announced that Jefferson VanderWolk will take over as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division at the Centre for Tax Policy and Administration (CPTA) in . . .

Europe

Tax officials address joint audits, public country-by-country reporting, developing country tax incentives

May 24, 2016

Tax experts, including officials from Germany, the IMF, World Bank Group, and OECD, offered their views on joint audits for multinational corporations, public country-by-country reporting, and tax incentives offered by developing countries at a conference held . . . 

No Picture
Belgium

Belgium’s excess profit tax ruling system: why the Commission thinks it’s illegal State aid

May 6, 2016

Professor Edoardo Traversa and Pierre Sabbadini analyze the EU Commission’s decision, made public May 5, that Belgium’s excess profit rulings tax scheme is illegal under State aid rules. . . 

Asia-Pacific

Australian tax office seeking to fast-track key court disputes with multinationals

April 21, 2016

The Australian Tax Office (ATO) is working with the Federal Court in an effort to “fast-track” the resolution of strategically important tax cases, Tax Commissioner Chris Jordan said April 21 at a Senate committee hearing on multinational corporation . . . 

Americas

Former US Treasury officials dispute proposed tax regulations combating inversions 

April 18, 2016

A group of 18 former US Treasury Department officials today sent a letter to Treasury Secretary Jacob J. Lew, urging the government to reconsider recently issued tax regulations aimed at stopping US companies . . .

Featured News

Countries that accept BEPS minimum standards may participate in global tax effort, OECD says

February 23, 2016

Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according . . .

Asia-Pacific

Japan, Greece to commence tax treaty negotiations

May 7, 2019

Japan’s Ministry of Finance has announced that . . .

Europe

Russian State Duma approves MLI: Russia Business Today→

April 19, 2019
Asia-Pacific

Australian tax office issues guidance on targeted integrity rules for hybrid mismatches

April 9, 2019

The Australian Taxation Office (ATO) on April 5 issued . . .

Asia-Pacific

Georgia deposit MLI ratification instrument

April 1, 2019

Georgia has deposited . . .

Featured News

Countries approve OECD proposal on VAT/GST collection by digital platforms

March 25, 2019

MNE Tax contributing editor, Davide Anghileri of the University of Lausanne, discusses the fifth Global Forum on VAT meeting in Melbourne, held March 20-22, where more than 100 jurisdictions, endorsed an OECD report on the role of digital platforms in the collection of VAT/GST on online sales . . ..

Digital Economy

Part one: OECD tax consultation on digitalization features 50+ speakers, diverse viewpoints (pillar one)

March 21, 2019

More than 50 international tax and transfer pricing experts from business, academia, labor, and non-governmental organizations spoke at a March 13–14 consultation, held at the OECD in Paris, on the tax challenges of digitalization. This article addresses the first day of the consultation which concerned the “pillar one” policy proposals . . .

Asia-Pacific

India, US reach agreement on country-by-country reporting for multinational groups

March 19, 2019

Madhan N, a partner at PricewaterhouseCoopers Private Limited, India, writes that the US and India have agreed to a country-by-country report exchange framework that will affect on MNE filing requirements . . .

Europe

Germany considering new R&D tax break, sources say: Michael Nienaber / Reuters→

February 26, 2019

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
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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Search MNE Tax

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
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019

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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.