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Americas
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Asia-Pacific
Indian flavors in transfer pricing master file, country-by-country rules
Jitendra Jain, Executive Director at PricewaterhouseCoopers, India, discusses India’s much-awaited rules on the implementation of the master file and country-by-country report, released yesterday, focusing on the differences between India’s master file requirement and the OECD’s prescribed format and recommending next-steps to comply with the requirements . . .
Asia-Pacific
Europe
Multinational
Africa
Americas
Americas
Americas
Europe
EU Parliament approves public country-by-country for multinationals
Today, the EU Parliament approved a proposal for a directive of the European Parliament and of the Council amending Directive 2013/34/EU as regards the disclosure of income tax information by certain undertakings and branches, writes Davide Anghileri of the University of Lausanne . . .
Estonia
Europe
EU Presidency offers compromise proposal for public country-by-country tax reporting by multinationals
Malta, as holder of the EU Presidency, has offered a compromise proposal to the EU Council that would require large multinational enterprises to publicly disclose tax information on a country-by-country basis, writes Davide Anghileri of the University of Lausanne . . .
Europe
Europe
Multinational
Europe
Americas
Africa
Europe
French rule denying tax deferral on merger is contrary to EU law, court rules
JP Canavan discusses the EU Court of Justice’s highly anticipated decision in the Euro Park Service case, which further defines the limits of EU Member States’ ability to restrict tax deferral benefits on mergers, reorganizations, and similar transactions . . .
Africa
South Africa identifies taxes qualifying for tax treaty relief
Davide Anghileri of the University of Lausanne writes about new guidance issued by the South African Revenue Service that identifies taxes that are similar to income taxes and thus qualify for tax treaty relief . . .
Austria
Multinationals asked to critique tax dispute resolution processes in Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden
The OECD has today asked global businesses to assess the mutual agreement procedure (MAP) for resolving tax treaty disputes in Austria, France, Germany, Italy . . .
Americas
US IRS issues final tax regulations on disregarded stock in inversions
The US IRS has published final and temporary (TD 9812) and proposed (REG-135734-14) tax regulations under section 7874 designed to fight tax avoidance associated with the inversion . . .
Asia-Pacific
India, Singapore sign tax treaty protocol: Central Board of Direct Taxes→
See: Release. The protocol will be analyzed in detail in a future MNE Tax article.
Asia-Pacific
India clarifies taxation of indirect transfers of assets abroad
India on December 21 set out a series of questions and answers clarifying the taxation . . .
Americas
US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives
The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . .
Europe
EU publishes CCTB, CCCTB, ATAD II directives proposing major tax reform for multinationals
Paulus Merks, Jian-Cheng Ku, and Jesse Peeters of DLA Piper, Amsterdam, discuss today’s release by the EU Commission of three tax directives, the CCTB, CCCTB, and ATAD II, which will potentially have a significant impact on multinationals operating in the European Union . . .
Americas
Americas
Americas
New Zealand proposes rules to combat multinational tax avoidance through use of hybrid mismatches
The New Zealand government has today released for discussion proposed measures to prevent multinational corporations from avoiding tax through use of hybrid mismatch . . .
