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Latest

Featured News

OECD releases 42 comments on transfer pricing guidance for hard-to-value intangibles

July 5, 2017

The OECD today released 42 comment letters responding to draft guidance that seeks to create a common method for tax administrations to implement Chapter VI of the OECD . . .

Americas

Bahamas budget includes reduction in business license tax: KPMG→

June 29, 2017
Americas

Canada takes conservative approach to multilateral instrument: Gowling WLG→

June 15, 2017
No Picture
Europe

Swiss panel offers revised corporate tax reform proposal

June 1, 2017

A steering group charged with preparing a new plan for Swiss corporate tax reform has presented its objectives and recommendations, called Tax Proposal 17, writes
Davide Anghileri of the University of Lausanne . . .

Asia-Pacific

India confirms intent to sign BEPS multilateral instrument curbing tax avoidance

May 17, 2017

Mansi Seth and Afaan Arshad of Nishith Desai Associates discuss today’s announcement that the Indian Union Cabinet has approved India’s signing of the multilateral instrument (MLI) to implement the tax treaty measures in the OECD/G20 base erosion profit shifting (BEPS) action plan . . .

Americas

Brazil’s country-by-country reporting obligation

May 10, 2017

Francisco Lisboa Moreira, an attorney with Castro, Barros, Sobral, Gomes, discusses Brazil’s country-by-country reporting requirement for large multinationals, identifying unresolved questions associated with the new rules . . .

Asia-Pacific

Singapore, Latvia sign tax treaty protocol

April 25, 2017

Singapore and Latvia have signed a protocol to amend their tax treaty, Singapore’s Inland Revenue Service has announced. The new agreement . . .

G20

The G20’s role in setting international tax standards reviewed: Sieb Kingma & Marcel GH Schaper / SSRN→

March 26, 2017

See: SSRN.

Asia-Pacific

China signs first APA for cost sharing agreement: PWC→

March 16, 2017

See: PWC. 

Europe

New Luxembourg transfer pricing rules may require documentation revision: KPMG Luxembourg→

March 2, 2017

See: KPMG Luxembourg.

Africa

South Africa Budget includes dividend withholding tax increase

February 27, 2017

Dr. E. Brincker of Cliffe Dekker Hofmeyr, Johannesburg, discusses international tax proposals in the South Africa budget, delivered February 22, that will affect multinational corporations . . .

Europe

German limit on tax deduction for related-party royalty payments approved by cabinet

January 31, 2017

The German cabinet has approved a draft law limiting tax deductions for cross-border royalty payments to related parties, writes Berlin-based practitioner, Ninja-Antonia Reggelin . . .

Asia-Pacific

Australian transfer pricing guidance on marketing, sales and distribution hubs released

January 17, 2017

Davide Anghileri of the University of Lausanne writes about key guidance released by the Australian taxation office January 16 setting out the ATO’s approach to transfer pricing issues related to marketing, sales and distribution, and other hubs . . .

Americas

Taiwan, US sign Model 2 FATCA IGA

January 3, 2017

Taiwan and the US signed a Model 2 FATCA intergovernmental agreement (IGA), according to an update on the US Treasury . . .

Featured News

OECD officials outline international tax initiatives, country-by-country reporting guidance released

December 5, 2016

OECD officials, during a December 5 webcast, discussed OECD international tax work, including just-released guidance implementing country-by-country reporting standards, the G20’s tax agenda, the BEPS multilateral instrument, OECD drafts on profit splits . . .

Asia-Pacific

India-Korea tax treaty enters into force

October 27, 2016

A double tax treaty signed by India and Korea on May 18, 2015, entered into force on September 12, the government of India announced . . .

No Picture
Europe

Swiss bank can’t reveal client’s account administrator or referring law firm to US, court rules

October 6, 2016

Switzerland’s Federal Supreme Court, in a decision made public yesterday, has concluded that a bank in the Swiss Canton of Ticino is prohibited from divulging the names of lawyers and a law firm associated with the bank’s US clients to the US IRS and Department of Justice, writes guest author Davide Anghileri . . . 

Asia-Pacific

Singapore and UK tax authorities agree to automatic exchange of financial account information

September 20, 2016

The Inland Revenue Authority of Singapore has announced that Singapore and the United Kingdom have signed a competent authority agreement establishing . . .

Asia-Pacific

Singapore, Australia sign agreement to share information to combat tax evasion

September 7, 2016

Singapore and Australia’s tax offices have signed an agreement to share data in an effort to crack down on tax evasion, the Australian tax authority. . .

Americas

Canada releases draft tax legislation to implement 2016 budget proposals

August 5, 2016

Kabir Jamal, an attorney with Goodmans LLP, Toronto, reports that the Canadian government has just released for consultation draft tax proposals to implement measures in Budget 2016 . . . 

Europe

Irish tax authority introduces formal bilateral advance pricing agreement program

June 23, 2016

Irish Revenue has today released guidelines establishing a formal bilateral advance pricing agreement (APA) program to provide certainty for multinational corporation transfer pricing . . .

Americas

MNEs managing business in US could inadvertently create a US partnership, authors warn: Jeffery M. Kadet and David L. Koontz / SSRN

May 5, 2016

See: SSRN.

No Picture
Europe

EU proposal likely to require public disclosure of MNE tax haven profits, taxes paid, etc. on a country-by-country basis, sources say: Jennifer Rankin / The Guardian→

April 8, 2016

See: The Guardian. Related: MNE Tax.

Germany

OECD releases 28 comments to draft on tax treaty residence of pension funds

April 6, 2016

The OECD on April 6 released public comments to a discussion draft intended to clarify the tax treaty residence of pension funds. The discussion draft, part of follow-up work . . .

Asia-Pacific

US and OECD approve of India’s data systems for transmission of confidential country-by-country reports, sources say: Remya Nair / Livemint→

April 1, 2016

See: Livemint.

No Picture
Europe

Swiss Canton Vaud backs 13.8 percent corportate tax rate from 2019: Froreip→

March 29, 2016

See: Froreip. More: MME Legal, Swissinfo. 

Asia-Pacific

Australian bill imposes GST on digital products and other intangibles supplied by nonresidents

February 10, 2016

Australia’s Treasurer on February 10 introduced into Parliament a bill that would impose the 10 percent goods and services tax (GST) to all supplies by nonresidents to Australian consumers except for supplies of goods and real property. A second measure . . .

No Picture
Americas

Switzerland Ecuador tax treaty protocol enters into force

May 7, 2019

The Swiss government today announced that . . .

Americas

Japan, Uruguay agree in principle to tax treaty

April 19, 2019

The Japanese and Uruguay governments have agreed in principle on a tax treaty . . .

Asia-Pacific

Australian tax office issues guidance on thin cap arm’s length debt test

April 9, 2019

The Australian Taxation Office on April 5 issued a draft taxation ruling (Tr 2019/2) addressing . . .

Asia-Pacific

Multilateral tax treaty enters into force in Singapore affecting 14 bilateral treaties

April 1, 2019

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered . . .

Americas

Colombia clarifies that dividend tax won’t apply to dividends paid from pre-FY 2017 profits: EY→

March 14, 2019
Council of the European Union

EU agrees to more details about coming rules requiring online marketplaces to collect VAT

March 12, 2019

EU Member States today reached political agreement on details regarding when an online marketplace will be responsible for ensuring . . .

Digital Economy

EU states set to scrap digital tax plan, to work for global reform: Reuters→

March 6, 2019
Asia-Pacific

Papua New Guinea signs the BEPS MLI

January 24, 2019

Papua New Guinea on January 23 signed the . . .

Americas

OECD tax officials visit Cayman after Dutch tax blacklisting, “One should first think about what a tax haven is, before putting that label on the Cayman Islands,” says Pascal Saint Amans:  Cayman Islands Financial Services→

January 14, 2019

Prior coverage: MNE Tax

Americas

Economic Partners acquired by Dallas-based tax firm Ryan

December 5, 2018

Ryan, a global tax services and software provider based in Dallas, Texas, announced . . .

Europe

Germany should consider patent box, reject minimum tax, expert panel concludes

November 19, 2018

Dominika Langenmayr, Professor of Economics at Catholic University of Eichstaett-Ingolstadt, discusses the German Council of Economic Experts’ November 7 report to the German government, focusing the council’s tax policy proposals regarding a minimum tax, digital tax, CCCTB, and patent box . . .

Digital Economy

Spanish government proposes digital services tax

October 24, 2018

Alma Virto, a Ph.D. candidate at the University of Salamanca, writes that Spain’s Council of Ministries on October 19 proposed a digital services tax on large tech companies . . .

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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

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • Indian court stays controversial Mastercard tax decision on permanent establishment by Staff | posted on October 29, 2018
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • AgraCity’s Canada transfer pricing dispute: co-distribution and the markup for logistics by Dr. Harold McClure | posted on September 2, 2020
  • Singapore adopts BEPS-compliant IP tax incentives by Edmund Leow | posted on March 24, 2021
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Transfer pricing in the times of COVID-19: do’s and don’ts for adjusting comparable company searches by Hugo Chary | posted on May 26, 2020

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