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Americas

More multinationals applying for US advance pricing agreements, statistics show

March 31, 2016

The US IRS on March 31 released statistics on the performance of the IRS’s Advance Pricing Mutual Agreement Program (APMA), revealing that taxpayers submitted . . .

Europe

UK’s HMRC rejects allegation that Google got a special deal in tax settlement

February 9, 2016

The UK’s HM Revenue and Customs on February 9 denied that Google received a “sweetheart deal” in a settlement that allowed the company to pay £130 million (USD 185 million) to resolve ten years of back taxes. The settlement, announced by Google on . . .

Asia-Pacific

Arbitration sought over Nepal tax bill stemming from acquisition of telecommunications provider: Mobile World Live→

April 30, 2019

Europe

EU Commission assessing whether probe needed to determine if Ireland aids to Google regarding tax: Dara Doyle & Aoife White / Bloomberg→

April 16, 2019

Asia-Pacific

Japan, Uruguay to negotiate tax treaty

April 8, 2019

apan’s Ministry for Finance has today announced that . . .

Americas

Marjorie Rollinson rejoins EY as Deputy Director of National Tax

March 7, 2019

Former US IRS Associate Chief Counsel (International) Marjorie Rollinson has rejoined . . .

Armenia

Armenia joins “Inclusive Framework on BEPS” to fight MNE tax avoidance

February 11, 2019

Armenia has joined the “Inclusive Framework on BEPS,” an OECD-led coalition of countries . . .

Austria

EU digital services tax may face legal challenge on multiple fronts: Hamza Ali & Isabel Gottlieb / Bloomberg Tax→

January 23, 2019

Asia-Pacific

China plans company tax cuts, VAT reform: Reuters→

January 11, 2019

Asia-Pacific

China’s new tax on foreign workers takes effect: Sidney Leng / South China Morning Post→

January 2, 2019

Africa

G20 leaders seek improved international tax system based on tax treaties, transfer pricing rules

December 3, 2018

G20 leaders, in a communique issued after their summit in Buenos Aires, Argentina, reaffirmed their commitment to improving the international tax system . . .

Asia-Pacific

Synthesized text of New Zealand-UK tax treaty reflects MLI changes

November 6, 2018

The UK government today released the synthesized text of the UK-New Zealand tax . . .

Europe

“Synthesized text” of UK-Slovenia tax treaty reflects MLI changes

October 11, 2018

The UK government today released the synthesized text of the 2007 UK-Slovenia tax treaty, prepared . . .

Europe

Draft German rules require reporting of cross-border tax planning

September 17, 2018

German tax practitioner Ninja-Antonia Reggelin discusses an unpublished discussion draft presented to the states last week by the German Federal Ministry of Finance that implements an EU directive requiring intermediaries to report cross-border tax planning arrangements . . .

Asia-Pacific

Australia passes tax rules on hybrid mismatches, approves MLI

August 28, 2018

Australian laws designed to curtail multinational tax avoidance through hybrid mismatch and branch mismatch arrangments and . . .

Asia-Pacific

Australia hybrid mismatch law passes parliament, awaits Royal Assent: EY→

August 18, 2018

Europe

EU Commission opens state aid investigation into Portugal’s Madeira Free Zone tax scheme

July 6, 2018

The EU Commission on July 6 announced that it is investigating for potential state aid violations the implementation of a tax exemption scheme put in place by Portugal . . .

Africa

Nigeria publishes country-by-country reporting regulations: KPMG→

June 28, 2018

Europe

At least 48 companies could be caught by EU State aid probe into UK CFC group financing exception: Bloomberg→

June 21, 2018

Europe

Serbia ratifies multilateral tax treaty to implement BEPS

June 7, 2018

Serbia on June 5 deposited with the OECD ratification documents for the Multilateral Convention to . . .

Asia-Pacific

Israeli tax authority may need to refund VAT paid by publishers that received payments for ad space sold to Google Ireland: Bloomberg Tax→

May 23, 2018

Europe

Christine Beernaerts joins Loyens & Loeff’s Luxembourg tax practice

May 23, 2018

Loyens & Loeff, Luxembourg, announced May 2 that international tax lawyer Christine Beernaerts . . .

Asia-Pacific

Singapore court rejects challenge to information exchange under tax treaty: IRAS→

May 16, 2018

Europe

Italy issues final transfer pricing regulations addressing arm’s length standard

May 15, 2018

Davide Anghileri of the University of Lausanne discusses final transfer pricing regulations issued by Italy’s Ministry of Economy and Finance on May 14 on the application of the arm’s length principle . . .

Asia-Pacific

Facebook Australia settles with tax authority, pays AUD 31m (USD 23.2 m) more for tax years 2009–2015: Chris Duckett / ZDNet→

May 3, 2018

Asia-Pacific

Macao, Vietnam sign tax agreement

April 17, 2018

Macao and Vietnam tax officials have signed an agreement to prevent double taxation, Macao’s SAR has reported. The agreement, signed April 16, covers . . .

Asia-Pacific

Pakistan releases more draft amendments to country-by-country reporting rules for MNEs

February 12, 2018

Pakistan’s government on February 9 published more amendments to draft rules that establish transfer pricing documentation and country-by-country . . .

Europe

Michael Gladney appointed Irish Revenue Commissioner

February 8, 2018

Michael Gladney has been appointed Ireland’ Revenue Commissioner, succeeding Liam Irwin, Irish Revenue . . .

Africa

South Africa appoints new chief officer of customs and excise

January 31, 2018

The South African Revenue Service (SARS) announced January 30 that its chief officer of customs and excise, Jed Michaletos, has resigned and that Teboho Mokoena will take . . .

Asia-Pacific

Thailand’s Cabinet agrees to law requiring transfer pricing documentation: The Nation→

January 11, 2018

Multinational

Professors assess firm, tax profession, and civil society success in lobbying BEPS Project: Christina Elschner, Inga Hardeck & Marcel Max / ResearchGate→

January 4, 2018

Congo’s lower house passes law raising mining tax: Aaron Ross / Reuters→

December 11, 2017

OECD approves model tax treaty update

November 24, 2017

The OECD council on November 21 approved a 2017 update to the OECD model tax convention. These changes will be incorporated into the model and published in the next few months, the OECD said. The update implements . . .

Europe

Barriguete joins Duff & Phelps’s Madrid transfer pricing practice

November 4, 2017

Pilar Barriguete has joined Duff & Phelps’s transfer pricing services practice in Madrid, the firm announced . . .

Americas

Canadian appeals court overturns decision in Univar, concludes GAAR does not apply to paid-up-capital planning during acquisition: EY→

October 23, 2017

Asia-Pacific

Australian bill excludes passive investment companies from lower tax rate

October 18, 2017

The Australian government today introduced legislation clarifying that passive investment companies will not qualify for the lower 27.6 percent company tax rate. Under the bill, a company will not qualify for the lower . . .

Asia-Pacific

Japan, Denmark sign new tax treaty

October 12, 2017

The governments of Japan and Denmark on October 11 signed new tax treaty, Japan’s Ministry of Finance has announced. The new treaty, signed in Tokyo, would amend the countries’ 1968 tax treaty, revising the taxation . . .

European Commission proposes major EU VAT reform

October 5, 2017

Davide Anghileri of the University of Lausanne, an MNE Tax contributing editor, discusses an EU Commission proposal, unveiled October 4, for EU-wide reform of VAT . . .

Asia-Pacific

Hong Kong considers new intragroup tax loss rules

September 26, 2017

Stefano Mariani and James Tong of Deacons, Hong Kong, discuss a proposal offered by a high-level government advisory panel on September 11 for a new Hong Kong intragroup tax loss transfer regime . . .

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

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” 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