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Latest

Europe

Russian court supports taxpayer in challenge to transfer pricing method: CMS→

September 11, 2017
Americas

US to exchange country-by-country reports with Australia, Estonia

August 3, 2017

The US IRS today announced that it has entered into separate agreements with Australia and Estonia to exchange country-by-country reports . . .

No Picture
Bulgaria

Bulgaria, Cyprus, Portugal must comply with exchange of tax ruling directive, Commission says

July 13, 2017

The EU Commission today called on Bulgaria, Cyprus, and Portugal to transpose into their laws EU measures requiring the automatic exchange of tax rulings between EU tax authorities . . .

Featured News

OECD “MLI Matching Database” for tax treaties goes live

July 10, 2017

The OECD made public its “MLI Matching Database” for tax treaties in beta this week. The database will assist in determining whether an in-force tax treaty . . .

Africa

US has agreed to country-by-country tax info exchange with 11 countries, OECD says

June 22, 2017

The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .

No Picture
Council of the European Union

EU adopts directive halting multinational tax avoidance through hybrid mismatches with third countries

May 29, 2017

Davide Anghileri of the University of Lausanne writes about today’s decision by the Council of the European Union to adopt a directive regarding hybrid mismatches with third countries, known as ATAD 2  . . . 

Europe

Russian draft law on country-by-country reporting introduced: DLA Piper→

May 5, 2017
Europe

Netherlands issued 539 private tax rulings in 2016, fewest since 2010: Pearse Trust→

April 20, 2017
Africa

Hong Kong agrees to automatic exchange of tax information with South Africa and Portugal

April 5, 2017

Hong Kong has agreed to automatic exchange of financial account information in tax matters with the governments of South . . .

Africa

Singapore, Ghana sign tax treaty

April 5, 2017

Singapore and Ghana have signed tax treaty, the Inland Revenue Authority of . . .

Asia-Pacific

Japan 2017 tax reform bill enacted: EY→

March 30, 2017

See: EY.

Americas

Amazon wins $1.5 billion transfer pricing dispute in US Tax Court

March 24, 2017

Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to payments under a cost-sharing agreement (CSA) with a Luxembourg subsidiary. The transfer pricing adjustments would have increased. . . 

Multinational

UN portfolio assists developing countries counter base-eroding payments from interest, financing costs: UN Financing for Development→

March 15, 2017

See: Protecting the Tax Base of Developing Countries against Base-eroding Payments: Interest and Other Financing Expenses.

Americas

UVA professor analyzes tax EU State aid law as applied to tax rulings: Ruth Mason / SSRN→

March 1, 2017

See: SSRN.

Americas

Mnuchin sworn in as US Treasury Secretary

February 13, 2017

Steven T. Mnuchin was sworn in to serve as US Secretary of the Treasury on February 13. In this capacity, Mnuchin will be the principal. . .

Europe

Ireland’s legal arguments in Apple State aid tax case published

February 6, 2017

Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, discusses Ireland’s arguments in the Apple State aid case before the Court of Justice of the European Union, as revealed in the government’s summary of  legal proceedings, released today . . . .

No Picture
Europe

Luxembourg must allow court challenge to validity of French tax information exchange request, CJEU Advocate General says

January 11, 2017

EU law requires that a company be given the opportunity to challenge a tax information order issued to implement a tax exchange of information request on the grounds that the request lacks “forseeable relevance,” Advocate . . .

Americas

US IRS issues FATCA regulations, updates agreements for FFIs, QIs

January 3, 2017

The US IRS in late December issued a slew of FATCA guidance, including updated agreements for foreign financial institutions and qualified intermediaries (QIs). Included in the release were . . .

Asia-Pacific

Australia publishes tax bills of large domestic and foreign businesses

December 13, 2016

The Australian government on December 9 released its latest corporate tax transparency report, making public the 2014–15 tax details of 1,904 large . . .

Americas

WTO ruling prohibits Boeing’s Washington State tax break: BBC News→

November 28, 2016

See: BBC News. More: CBS News, Wall Street Journal, Seattle Times. Original Source: WTO.

Europe

Sweden proposes financial activities tax: KPMG→ 

November 26, 2016

See: KPMG. 

Europe

UK to reject EU Commission CCCTB plan: The Guardian→

October 21, 2016

See: The Guardian.

Americas

US Supreme Court denies certiorari in Gillette case which held MTC apportionment formula not binding on California: Lawrence Hurley / Reuters→

October 11, 2016

See: Reuters.

Asia-Pacific

Australia proposes new debt-equity tax rules

October 10, 2016

The Australian government has released draft legislation for public comment that would amend the country’s debt-equity tax . . . 

Europe

UK corporate tax rate will be 17 percent by 2020, Hammond confirms

October 3, 2016

UK Chancellor of the Exchequer Philip Hammond today confirmed that the government will stick to its plan to lower the UK corporate tax rate from 20 percent . . .

Europe

EU Commission scoreboard identifies non-EU countries that potentially enable tax avoidance

September 15, 2016

As part of an effort to devise an EU-wide common list of tax havens, the EU Commission today released a scoreboard designed to help identify countries located outside the EU that enable multinational corporation tax avoidance. Eighty-one countries – including the US, China, and India – were identified. . .

Americas

Japan, Panama sign tax information exchange agreement regarding Panama City

August 26, 2016

In an effort to combat tax evasion, Japan and Panama have signed a tax information exchange agreement relating to tax matters in Panama City, Japan’s . . .

Europe

UK to extend country-by-country tax reporting to partnerships

August 2, 2016

The UK’s HM Revenue and Customs today announced that it will propose amendments to existing country-by-country reporting regulations applicable to large multinational enterprises to add . . .

Asia-Pacific

India and Cyprus agree to revise tax treaty, remove Cyprus from tax blacklist

June 30, 2016

India and Cyprus have completed negotiations for a new tax treaty that allows for source-based taxation of capital gains from the alienation of shares and have agreed to Cyprus’s removal from India’s blacklist of “notified jurisdictional areas,” Cyprus’s . . . 

Asia-Pacific

Singapore and Cambodia sign tax treaty, text available

May 31, 2016

Singapore and Cambodia have signed a tax treaty, the Inland Revenue Authority of Singapore has . . .

Americas

Authors address US model tax treaty special tax regimes, subsequent law changes: Allison Christians & Alexander Ezenagu / SSRN→

May 20, 2016

See: SSRN

Europe

Polish draft bill taxes nonresidents’ capital gains on sales of Polish securities: EY→

April 29, 2016

See: EY

Asia-Pacific

Australian guidance details procedure when transfer pricing adjustments affect customs values

April 15, 2016

The Australian government has released details on the how the tax office (ATO) will respond to taxpayer requests for help determining customs duty values following a . . .

No Picture
Europe

Switzerland/France tax treaty amendments enter into force

March 30, 2016

Amendments to the 1966 tax treaty between Switzerland and France tax entered into force today enhancing . . .

Europe

UK Public Accounts Committee concludes it’s impossible to tell if £130 million Google tax settlement was fair: UK Parliament→

February 24, 2016

See: UK Parliament.

No Picture
Europe

Switzerland to sign BEPS country-by-country reporting multilateral agreement

January 20, 2016

Swiss tax officials intend to sign next week a multilateral agreement to implement country-by-country reporting developed under the OECD/G20 base erosion profit shifting (BEPS) plan, Switzerland’s Federal . . .

Americas

80+ US companies urge Congress to ratify pending tax treaties citing double taxation concerns: National Foreign Trade Council→

April 30, 2019
Asia-Pacific

Singapore describes how the MLI affects 14 of its bilateral tax treaties

April 5, 2019

The Inland Revenue Authority of Singapore (IRAs) has provided information about how . . .

Africa

Kenya High Court strikes down Mauritius / Kenya tax treaty in TJN Africa action: Will Fitzgibbon / ICIJ→

March 21, 2019

For background, see: TJN Africa’s challenge to “loophole-ridden” Kenya-Mauritius tax agreement to be heard in Kenya High Court.

Posts pagination

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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

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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

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
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    July 12, 2022
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    July 7, 2022
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    July 5, 2022
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    June 28, 2022

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