Latest – Page 79 of 157

Asia-Pacific

Australia sets enhanced cooperation with tax office as condition for foreign investment

February 22, 2016

Australian Treasurer Scott Morrison on February 22 announced that he will use his powers to block investment to force large multinationals and other foreign investors pay tax on Australian . . .

Asia-Pacific

Singapore-Ireland tax treaty MLI amendments enter into effect

May 2, 2019

The Singapore government has announced that amendments made to the Singapore-Ireland tax treaty as a result of . . .

Council of the European Union

Draft German law offers procedures to resolve double tax disputes

April 18, 2019

Tax practitioner Ninja-Antonia Reggelin discusses a German draft law published April 16 providing a scheme for resolving instances of double taxation . . .

Asia-Pacific

Australia publishes synthesized text of tax treaty with Slovak Republic as affected by the MLI: Australian Taxation Office→

April 9, 2019

Africa

Edward Kieswetter appointed South African Revenue Service Commissioner

March 29, 2019

Edward Kieswetter has been appointed Commissioner of South African Revenue . . .

International Monetary Fund

IMF paper proposes criteria for assessing international tax reform proposals: International Monetary Fund→

March 12, 2019

Europe

Spain, Britian sign Gilbraltar tax treaty: Aaj News→

March 7, 2019

Americas

US APMA using “Functional Cost Diagnostic Model” in bilateral APAs and MAP to assess transfer pricing where two or more parties contribute to business: PWC→

February 28, 2019

Belgium’s excess profits tax scheme is not State aid, EU court concludes

February 14, 2019

Professor and EU tax and state aid expert, Dr. Patricia Lampreave, discusses today’s European General Court decision annulling an EU Commission decision concerning Belgium’s excess profits tax scheme . . .

Europe

MNEs in EU pay lowest effective tax rate in Luxembourg (2.2 %), highest in Norway (48.7%), study says: EU Parliament, Greens/EFA Group→

January 23, 2019

Multinational

OECD releases corporate tax statistics analyzing revenues, statutory and effective rates, tax incentives for innovation: OECD→

January 22, 2019

Americas

Key takeaways from the proposed foreign tax credit regulations

December 19, 2018

Amanda Varma and Greg Kidder of Steptoe & Johnson LLP, Washington, analyze the proposed foreign tax credit regulations released on November 23 . . .

Bulgaria

Bulgaria tax changes introduce first CFC rules, modify thin cap provisions

December 4, 2018

Ivan Dimitrov discusses important tax changes introduced in Bulgaria last week, including the country’s first-ever controlled foreign company (CFC) rules and revisions to the thin capitalization regime . . .

French minister asks for EU Parliament support on digital services tax: European Parliament→

October 23, 2018

EU Parliament members seek higher tax rate for temporary digital services tax: Samuel Stolton / EURACTIV→

October 11, 2018

Americas

Five highlights from the IRS’s proposed GILTI regulations

October 1, 2018

Amanda Varma and Greg Kidder of Steptoe & Johnson LLP, Washington, discuss in detail US regulations issued September 13 addressing the new global intangible low-taxed income (GILTI) regime . . .

Asia-Pacific

Saudi Arabia signs BEPS MLI to combat tax avoidance

September 18, 2018

The OECD today announced that Saudi Arabia has signed a multilateral tax treaty designed to allow countries to swiftly add to their existing bilateral tax treaties additional provisions . . .

Multinational

Patent boxes may not encourage innovation, academics say: Fabian Gaessler, Bronwyn H. Hall, & Dietmar Harhoff / SSRN→

August 22, 2018

Europe

Diageo pays UK £199 million (USD 250 million) in transfer pricing settlement to avoid DPT: Ben Stupples / Bloomberg Tax→

July 30, 2018

Americas

OECD asks MNEs for feedback on cross-border tax dispute resolution in Argentina, Chile, Colombia, Croatia, India, Latvia, Lithuania, South Africa

July 26, 2018

The OECD is seeking feedback on multinationals’ experience with cross-border tax dispute resolution procedures in . . .

Europe

UK publishes final MLI reservations and notifications

July 17, 2018

The UK has published its final list of reservations and notifications to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base . . .

Multinational

Paper addresses mandatory disclosure rules, effect of time lag between innovation or imitation of aggressive tax planning products and regulatory action: Kai A. Konrad/SSRN→

June 26, 2018

Europe

UK to publish draft tax legislation

June 18, 2018

The UK government will publish draft tax changes for its next finance bill on . . .

Americas

New OECD project aims to encourage proper use of tax treaty principal purpose test, official says

June 10, 2018

The OECD is working on a project designed to encourage tax administrations to act reasonably when interpreting and applying the principal purpose test, an official said at the 2018 OECD International Tax Conference, held . . .

Americas

US Federal court grants IRS motion to dismiss Facebook suit, says company has no right to IRS Appeals in transfer pricing challenge: Leslie Book / Procedurally Taxing→

May 16, 2018

Digital Economy

Spain to propose digital services tax beginning 2019

May 9, 2018

The Spanish government has announced it will propose a temporary tax on digital company revenue this year, aiming for the new tax to take effect in 2019, writes Alma Virto. a researcher and PhD candidate at the University of Salamanca, Spain . . .

What's New

US IRS extends exception from US property for certain notional principal contracts

May 6, 2018

The US IRS on March 4 announced that taxpayers may continue to rely on the exception to United States property in §1.956-2T(b)(1)(xi) past its May 7 sunset . . .

Swiss Federal Council approves tax agreements with Ecuador and Zambia

April 18, 2018

Switzerland’s Federal Council on April 18 approved a new tax treaty with Zambia and a protocol amending Switzerland’s tax treaty with Ecuador. The new . . .

International Monetary Fund

MNEs move operations when countries adopt transfer pricing regulations, IMF paper says: Ruud A. de Mooij & Li Liu / IMF→

March 27, 2018

Americas

US tax reform seeks return of IP to US: Sam Schechner / Wall Street Journal [paywall]→

February 1, 2018

Americas

Mexico: transfer pricing 2017 year-in-review

January 11, 2018

Yoshio Uehara and Ignacio Mosquera of Chevez, Ruiz, Zamarripa y Cía., Mexico City, offer an overview of the most important transfer pricing developments in Mexico in 2017, noting it was a very active year and focusing on new transfer pricing guidance . . .

Europe

Dutch taxation of multinationals: a 2017 year-in-review and look forward to the future

January 8, 2018

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, write that 2017 was a year of significant change for Dutch tax law and international tax law; the authors predict that 2018 will be just as dynamic . . .

Americas

Royalty, interest withholding tax rates drop under Ireland-Chile tax treaty

December 12, 2017

Ireland’s government today announced that withholding tax rates for interest and royalties will drop under the Ireland-Chile tax treaty according to the terms . . .

Americas

Medtronic and IRS battling $1.4 billion transfer pricing case in US federal court: Joe Carlson / Star Tribune→

November 28, 2017

Europe

Markov and team move from Deloitte to Dentons, St. Petersburg

November 27, 2017

Vasilii Markov has joined Dentons as partner and head of the St. Petersburg tax group, the firm announced November 23. Markov joins from Deloitte, and takes with him seven Deloitte tax . . .

Europe

Dutch tax consolidation regime violates EU law, advocate general concludes

November 7, 2017

Jian-Cheng Ku, Tim Mulder, and Rhys Bane of DLA Piper, Amsterdam, discuss the CJEU Advocate General’s opinion, delivered October 25, concluding that, following the Groupe Steria decision, aspects of the Dutch tax consolidation regime violate EU concepts of freedom of establishment and are thus contrary to EU law . . .

OECD releases cross-border VAT implementation guidance

October 24, 2017

The OECD today released guidance designed to assist policy makers in their effort to evaluate and develop the legal and administrative framework for collecting VAT on cross-border sales. The . . .

Americas

Economist Kirk Hesser to lead Cherry Bekaert’s US transfer pricing practice

October 12, 2017

Economist Kirk A. Hesser has joined Cherry Bekaert as US leader of the firm’s transfer pricing services group and managing director of its Atlanta practice. Hesser is formerly managing director of transfer pricing at BDO, where he worked for 7 years, and has also worked. . .

Asia-Pacific

Japan’s tax agency issues Q&A on mutual agreement procedure: KPMG→

October 5, 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.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin