Latest – Page 70 of 157

Americas

“Marketing intangibles” solution to global digital tax dispute should apply only to consumer-facing businesses, US official says

February 19, 2019

A US-backed proposal for globally coordinated rules allowing market countries to tax a greater share of multinational firm profits based on “marketing intangibles” should be limited to businesses that ultimately sell to . . .

Europe

First look: UK guidance aims to help MNEs come into compliance with transfer pricing laws

January 10, 2019

The UK’s HM Revenue and Customs today issued a “Profit Diversion Compliance Facility” offering multinationals the opportunity to . . .

Asia-Pacific

Australia updates tax guidance on central managment and control test

December 6, 2018

The Australian Taxation Office on December 5 issued an update to draft guidance . . .

Americas

US adds many new international tax projects to priority guidance list

November 8, 2018

The US Treasury and IRS today released its 2018–2019 Priority Guidance Plan, detailing tax guidance the government . . .

Denmark

Denmark court says no deemed compensation in transfer pricing case involving restructuring

October 24, 2018

Michael Vorndran, Nord Advisory AS, discusses a new transfer pricing decision of Denmark’s National Tax Tribunal where the court rejects the tax authority’s assertion of additional taxes from the liquidation of a Danish subsidiary in a group-wide restructuring . . .

Asia-Pacific

New Zealand announces new R&D tax incentives

October 3, 2018

The New Zealand government today proposed a new research and development (R&D) tax incentive package designed to promote investment. Legislation providing for the credit will . . .

Multinational

Report alleges that four large drug companies allocate profits to tax havens to avoid tax: Oxfam→

September 23, 2018

Americas

Canadian Tax Court rules income from grocery firm Loblaw’s Barbadian banking subsidiary was taxable foreign accrual property income: BNN Bloomberg→

September 10, 2018

Africa

Singapore and Gabon sign tax treaty

August 29, 2018

The governments of Singapore and Gabon on August 28 signed a comprehensive tax treaty, the Inland Revenue . . .

Americas

Japan to negotiate tax treaty with Ecuador

August 24, 2018

Japan’s Ministry of Finance today announced that Japan and Ecuador will enter into . . .

Americas

New IRS manual aims to guide audit personnel in transfer pricing examination process

July 17, 2018

Marc M. Levey, a partner in Baker McKenzie’s New York office, discusses a new IRS manual designed for IRS agents called the Transfer Pricing Examination Process which may also be a helpful tool for taxpayers preparing for transfer pricing examinations . . .

EU proposes to fund budget through CCCTB: Eoin Burke-Kennedy / The Irish Times→

June 13, 2018

Digital Economy

Germany’s Merkel proposes tax on digital data: Xinhua→

May 30, 2018

Multinational

Professors explore how MNEs shift risk among affiliates to move profits to low-tax countries: Johannes Becker, Niels Johannesen, Nadine Riedel→

May 21, 2018

Americas

Indonesia waives local tax filing requirement for US-parented multinationals

April 28, 2018

Indonesia will not impose local filing obligations on constituent entities of US multinational groups tax resident in Indonesia respect to fiscal years commencing on or after January 1, 2016, even if the US and Indonesia do not reach a competent . . .

Americas

IRS attorney-advisor Ryan Kelly joins Alston & Bird

April 6, 2018

Ryan J. Kelly has joined Alston & Bird’s Washington, DC federal and international tax group as . . .

Americas

US IRS publishes final tax regs on allocation of research credit

March 28, 2018

The US IRS today published final regulations on allocation of the credit for increasing research activities among corporations and trades or businesses under common . . .

Egypt

Egypt to use EU grant to improve cross-border tax system, other tax policies: Ahram Online→

March 8, 2018

Americas

Anguilla joins”Inclusive Framework on BEPS” to fight MNE tax avoidance

March 6, 2018

Anguilla has joined the “Inclusive Framework on BEPS,” a group of now 113 nations that have pledged to work together to implement the OECD/G20 base erosion profit shifting (BEPS) project outcomes, the OECD announced . . .

Multinational

Transfer pricing rules should account for value created by exploitation of labor at price below living wage, allocating more profit to developing nations, professors say: Allison Christians & Van Apeldoorn→

March 4, 2018

Americas

US IRS provides instructions for amending country-by-country reports on multinationals

January 18, 2018

The US IRS today updated its frequently asked questions on country-by-country reporting to address how a US multinational enterprise (MNE) should proceed if it needs to to modify or correct a submitted Form 8975 and Schedule A. The Service said . . .

Americas

IRS transfer pricing directives address penalties, stock-based compensation, best method, CSA RAB shares, document requests

January 16, 2018

The US IRS’s Large Business and International (LB&I) division on January 12 issued five directives that provide administrative guidance to LB&I examiners relating to transfer pricing . . .

EU officials to recommend removal from tax blacklist for Panama, South Korea, UAE, Barbados, Grenada, Macao, Mongolia, Tunisia: Francesco Guarascio / Reuters→

January 16, 2018

Hungary and Ireland oppose EU-wide CCCTB to harmonize taxation: Carlo Motta / European Sting→

January 9, 2018

Asia-Pacific

Australia’s diverted profit tax clarified in new guidance

December 21, 2017

The Australian Taxation Office (ATO) on December 18 published two sets of guidance further clarifying it’s a diverted profits tax on large multinationals. The tax . . .

Europe

Luxembourg to contest Amazon State aid decision in EU court

December 15, 2017

The Luxembourg government today announced that it will appeal in General Court a European Commission decision that concluded that Luxembourg granted illegal State aid to Amazon’s Luxembourg subsidiary through a . . .

Asia-Pacific

South Korea protests inclusion in EU tax blacklist: the hankyoreah→

December 7, 2017

EU adopts new VAT rules for online sales

December 5, 2017

Today, the European Council adopted new rules revising the EU’s value-added tax (VAT) system that will make it easier for internet companies to sell to consumers located . . .

Europe

Flick Gocke Schaumburg to open new Düsseldorf office

November 27, 2017

Flick Gocke Schaumburg on November 20 announced that it will open a new office in Düsseldorf staffed with a team of tax and corporate lawyers. Transfer pricing . . .

EU Council approves new cross-border tax dispute resolution plan

October 10, 2017

As expected, the ECOFIN Council today approved a directive establishing a new system for resolving double taxation disputes between EU member states. The new directive on tax dispute resolution follows an agreement reached by EU nations on May 23. It was approved without discussion. Member states will have until June . . .

Europe

Catherine Harlow is new head of transfer pricing at AstraZeneca

September 26, 2017

Catherine Harlow is AstraZeneca’s new head of transfer pricing, taking on her new role earlier this month. Harlow, a frequent speaker at TP Minds and other transfer pricing . . .

Europe

France hits Microsoft with 600 million euro tax bill: L’Express→

September 25, 2017

Americas

Mike McDonald leaves US Treasury post for EY

September 20, 2017

Economist Michael McDonald has left the US Treasury Department to rejoin Ernst & Young in its National Tax Department – International Tax Services, Transfer Pricing, the firm announced today. McDonald was a financial . . .

Europe

UK tax authority details diverted profits tax, transfer pricing, patent box stats

September 16, 2017

UK tax authorities have released information on the diverted profits tax, transfer pricing program, and patent box. According to . . .

Germany, France plan to propose tax on internet firms at Sept. EU meeting: The Local→

August 30, 2017

Americas

Court rules Canadian tax authority can’t question executives in Cameco transfer pricing case: Drew Hasselback / Financial Post→

August 17, 2017

Asia-Pacific

Hong Kong’s plan to legislate BEPS: what to expect

August 14, 2017

Stefano Mariani and Calvin Ng of Deacons discuss the Hong Kong government’s July 31 announcements on its planned response to BEPS, which according to the authors, reveal that the territory will soon abandon its its longstanding stance as an easy and light-touch structuring jurisdiction . . .

OECD, UN, IMF, World Bank “toolkit” says countries should expand taxation of indirect asset transfers

August 2, 2017

The IMF, OECD, UN, and World Bank Group, through a joint initiative known as the “Platform for Collaboration on Tax,” has released a draft toolkit discussing proposed approaches for countries to adopt to address tax avoidance through . . .

Asia-Pacific

New Zealand to opt for diverted profits tax if Labor leads government: Audrey Young / NZ Herald→

July 19, 2017

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.
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