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US Tax Court decision has big implications for non-US partners in US partnerships
Monte A. Jackel, Senior Counsel at Akin, Gump, Strauss, Hauer & Feld, discusses the implications of the US Tax Court’s July 13 decision in Grecian Magnesite Mining, Industrial & Shipping Co. SA v. Commissioner, where the Court rejected the IRS’s aggregate approach for taxing a foreign partner’s gain on the redemption of its US partnership interest and concluded that the foreign investor was not subject to US taxation . . .
Tomas Balco appointed head of OECD transfer pricing unit
Tomas Balco has been appointed Head of the Transfer Pricing Unit in the OECD Centre for Tax Policy and Administration, the OECD announced . . .
India’s multilateral instrument choices: a quick run-through
Sriram Govind, a research and teaching associate at the Institute for Austrian and International Tax Law, discusses India’s choices for the multilateral instrument and possible implications to its tax treaty network . . .
Switzerland, Kosovo sign tax treaty
Switzerland and Kosovo on May 26 signed a tax treaty, agreeing to reduce withholding tax on dividends and royalties, the Swiss government has . . .
What the Chevron decision means for Australia and transfer pricing worldwide
Nick Drizen of BDO Australia discusses the Australian Full Federal Court’s landmark decision in Chevron, providing insight into transfer pricing for intercompany loans . . .
Mexico: transfer pricing documentation and country-by-country reporting rules finalized
Yoshio Uehara, César De la Parra, and Ignacio Mosquera of Chevez, Ruiz, Zamarripa, analyze final rules, issued by the Mexican tax authorities April 3, that implement the transfer pricing documentation and country-by-country reporting scheme set out in Action 13 of the OECD/G20 base erosion and profit shifting (BEPS) plan agreements . . .
UK country-by-country reporting guidance published
The UK’s HM Revenue & Customs (HMRC) today published a policy paper titled “Amendments to Country By Country reporting 2017” and an updated policy. . .
No withholding tax exemption for dividends paid to Dutch UCITS parent, court rules
Dublin-based tax specialist, JP Canavan, discusses a March 8 ruling of the Court of Justice of the European Union which concludes that dividends paid by a Belgian subsidiary to its parents, both Dutch UCITS, do not qualify for an exemption from Belgian withholding tax under the EU Parent-Subsidiary Directive . . .
Jeremy Cape joins Squire Patton Boggs, London
Squire Patton Boggs has today announced that UK international and Africa tax expert, Jeremy Cape, has joined the firm as a partner. Cape will join the firm’s Tax Strategy . . .
New India GAAR circular aims for clarity but remains unsatisfactory
Sriram Govind of the Institute for Austrian and International Tax Law discusses a circular issued by the Indian government January 27 which contains welcome clarifications on India’s coming GAAR but also includes statements that will likely increase confusion, such as how the GAAR will be applied in some cases involving tax treaties . . .
Italian tax agency issues first investment ruling, addresses logistics hubs
Davide Anghileri of the University of Lausanne discusses Italy’s January 17 release of its first investment ruling, which clarifies when a logistics hub located in Italy is a permanent establishment and covers the VAT treatment of goods flowing through such hubs . . .
Hong Kong and Belarus sign tax treaty, text available
Hong Kong’s Inland Revenue Department has announced that Hong Kong and Belarus signed a tax treaty on . . .
Updated Singapore transfer pricing guidance allows simplified method for related party loans
Singapore’s Inland Revenue Authority (IRAS) on January 12 published the fourth edition of its e-Tax Guide on transfer pricing. The new guidance includes a discussion . . .
Germany proposes tax deduction limits on royalties paid to related companies
Berlin-based tax specialist Ninja-Antonia Reggelin discusses a draft German law published in late December by the finance ministry which is designed to counter harmful foreign country tax practices through the disallowance of tax deductions for royalty payments made to related companies. . .
Australia-Germany tax treaty enters into force
A tax treaty signed between Australia and Germany entered into force on December 7, Australia’s . . .