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Latest

Asia-Pacific

Japan, Spain to negotiate tax treaty amendments

April 24, 2017

The governments of Japan and Spain will begin negotiations to amend their existing tax treaty, Japan’s Ministry. . .

Featured News

UN committee weighing major updates to model tax treaty, other guidance

April 3, 2017

The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . . 

Asia-Pacific

Australia expects large tax recoveries from seven multinational firm audits, Jordan says

March 16, 2017

The Australian Taxation Office (ATO) expects to conclude tax audits of at least seven major multinational firms by June 30, likely assessing combined tax liabilities in excess . . . 

Americas

US Sens. Sanders, Schatz introduce tax bill to end deferral of multinational profits, close loopholes

March 9, 2017

US Senators Bernie Sanders (I-Vt.) and Brian Schatz (D-Hawaii) today introduced a tax bill designed to curtail . . .

Americas

IRS announces issue-based campaign to increase tax compliance of large companies, international business

February 1, 2017

The US IRS has announced that it has selected 13 tax and transfer pricing topics that it will focus on in an issue-based campaign to increase the tax compliance of large and/or international businesses. In a January 31 announcement, the IRS’ Large Business and International division (LB&I) said it will . . .  

Americas

Trump says US House border-adjustment plan is overly complex: Richard Rubin & Peter Nicholas / WSJ→

January 17, 2017

See: WSJ. See also, The Hill.

No Picture
Council of the European Union

Luxembourg’s Juncker blocked EU code of conduct group anti-tax avoidance measures, leaks show: Simon Bowers / The Guardian→

January 4, 2017

See: The Guardian. More: Luxemburger Wort, RT.

Asia-Pacific

Japan, Switzerland exchange notes on automatic exchange of tax information

December 19, 2016

The Japan-Switzerland Joint Declaration Automatic Exchange of Information, signed in January 2016 will enter into force on 1 January 2017, writes Davide Anghileri of the University of Lausanne . . . 

Americas

US should adopt worldwide tax system without deferral, foreign tax credit, professors argue: J. Clifton Fleming, Robert J. Peroni, Stephen E. Shay / SSRN→

November 26, 2016

See: SSRN.

Americas

Guyana and Dominican Republic sign Model 1 FATCA IGAa with US

October 26, 2016

The US Treasury Department has updated its FATCA website, reporting that Guyana and the Dominican Republic have signed Model 1 intergovernmental . . .

No Picture
What We're Reading

Countries push for coordinated rules ensuring taxation of dividend, royalty payments leaving the EU: Joe Kirwin / Bloomberg BNA→

October 6, 2016

See: Bloomberg BNA.

Austria

Liechtenstein and Austria sign protocol to amend tax treaty

September 20, 2016

Liechtenstein and Austria have signed a protocol to amend their double tax agreement, the Liechtenstein government has announced. The agreement, signed . . .

Europe

Britain wont lower corporate rate to 15% say sources quoting Hammond: Bloomberg→

September 13, 2016

See: Bloomberg.

Asia-Pacific

China and Macao sign tax arrangement

September 7, 2016

Officials from China and the Macao Special Administrative Region signed a protocol to their tax arrangement following talks in Beijing. . .

Americas

US-Curaçao Model 1 FATCA agreement enters into force

August 5, 2016

US Treasury on August 5 announced on its website that a Model 1 FATCA intergovernmental agreement (IGA) signed by the US and Curaçao entered. . .

Asia-Pacific

New Singapore-France tax treaty enters into force

June 1, 2016

A revised tax treaty between Singapore and France entered into force on June 1, the Inland Revenue Authority . . .

Multinational

Investment flows through special purpose entities in offshore financial hubs surged in 2015, says UN report→

May 5, 2016

See: UNCTAD Global Investment Trends Monitor.

No Picture
More News

Switzerland launches consultation on exchange of multinational corporation country-by-country tax reports

April 15, 2016

Switzerland’s Federal Council on March 13 initiated a consultation on legislation that would give effect to a multilateral agreement signed . . .

Americas

Russia weighs sanctions against UK for permitting tax evasion through Cayman Islands and BVI: Kenneth Rijock / Caribbean News Now→

March 30, 2016

See: Caribbean News Now.

Asia-Pacific

Report details India’s plan for equalization levy to tax digital economy

March 22, 2016

The Indian government on Monday released a high level report that appears to have influenced Finance Minister Arun Jaitley’s budget proposal for a 6 percent equalization levy on e-commerce . . .

Americas

US MNEs may not file country-by-country reports with IRS for tax years prior to regs’ effective date, official says: Brant Goldwyn / CCH→

March 11, 2016

See: CCH.

India

Indian tax agency announces signing of seven more APAs

January 22, 2016

India has signed seven more unilateral advance pricing agreements (APAs) with multinationals, India’s Central Board of Direct Taxes (CBDT) announced January 22. The . . .

Americas

British Virgin Islands tax authority publishes draft code on economic substance

May 7, 2019

The British Virgin Islands International Tax Authority on April 23 published a draft . . .

Europe

German government proposes new R&D tax incentive

April 19, 2019

Ninja-Antonia Reggelin discusses a draft law published by the German finance ministry April 17 introducing a tax incentive for research and development . . . .

Europe

Italy to cut corporate rate to 20 percent, roll back individual income tax, leaked document says: Reuters→

April 9, 2019
Europe

Dutch state secretary clarifies Netherlands-Germany joint declaration on conditional withholding tax, minimum tax rate

April 1, 2019

Jian-Cheng Ku & Rhys Bane of DLA Piper Nederland N.V. discuss statements made by the Netherlands State Secretary of Finance, Menno Snel, that clarify the March 27 Netherlands-Germany joint declaration on international tax matters . . .

Europe

Ukraine transfer pricing guidance clarifies treatment of permanent establishments

March 25, 2019

Leonid Karpov, AC Crowe, discusses transfer pricing guidance issued by Ukraine’s tax authority on March 4 addressing transactions between a foreign company and its Ukrainian permanent establishment . . .

Featured News

OECD releases 200+ comment letters responding to key international tax consultation

March 8, 2019

The OECD today released more than 200 comment letters received in response to a public consultation which, while said to be focused on “the tax challenges of the digitization of the economy,” has morphed into . . .

Europe

Ukraine ratifies MLI to amend tax treaties

March 4, 2019

Leonid Karpov of AC Crowe, Ukraine writes that on March 1 Ukraine’s Verkhovna Rada adopted the President’s bill concerning the ratification of the MLI . . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

Amazon to again pay $0 US federal tax despite 2018 profits of $11.2b, citing unspecified tax credits, executive stock option break: Matthew Gardner / ITEP→

February 16, 2019
Europe

The new UK “Profit Diversion Compliance Facility”: what MNEs need to know

January 13, 2019

Liz Hughes of Grant Thornton UK LLP discusses the UK’s new “Profit Diversion Compliance Facility,” issued on 10 January, which is designed to encourage groups with arrangements that might fall within the scope of the diverted profits tax to amend their transfer pricing policies . . .

Americas

Google shifted USD 23 billion income to tax haven Bermuda in 2017 using Dutch shell company: Reuters→

January 4, 2019
Europe

Ireland records first budget surplus since crash aided by record collection of €10.4 billion in corporation tax, largely from multinationals: Eoin Burke-Kennedy / The Irish Times→

January 3, 2019
No Picture
Council of the European Union

Germany, France propose stripped-down version of digital services tax 

December 5, 2018

French and German finance ministers on Tuesday presented yet another compromise proposal for an EU-wide digital services tax, this time . . .

Africa

Zimbabwe to impose 2 cents per dollar tax on electronic transactions: Crecey Kuyedzwa / Fin24→

October 3, 2018
No Picture
Europe

New Switzerland-Latvia tax treaty protocol enters into force

October 2, 2018

The Swiss government today announced that a protocol to its 2002 tax treaty with . . .

Africa

New Nigerian transfer pricing regs promote compliance, official says: Peter Uzoho / THISDAYLIVE→

September 20, 2018
Asia-Pacific

Australian PM drops plan to cut large corporation tax rate from 30 percent rate to 25 percent: Cathy Zhang / The Epoch Times→

August 23, 2018

Posts navigation

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What’s Next

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May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
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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
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Singapore adopts BEPS-compliant IP tax incentives by Edmund Leow | posted on March 24, 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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