William Alexander will join Skadden, Arps, Slate, Meagher, & Flom’s Washington, DC office, the firm announced January 8. Alexander, who has been with the IRS Office of Chief Counsel since 1990 and served as IRS associate chief counsel (corporate) for the last 12 years, will join Skadden’s global tax group . . .
The Chinese government has finalized administrative measures implementing its general antiabuse rule (GAAR), the State Administration of Taxation (SAT) announced December 12. The guidance implements GAAR rules introduced in 2008, addressing the law’s scope, judging criteria, adjustment methods, working procedures, and dispute resolutions, the SAT said in . . .
The UK government will introduce a new “diverted profits tax” to ensure that multinational corporations pay the correct about of tax, British Chancellor of the Exchequer, George Osborne, announced December 3 in his Autumn Statement. The UK also released a consultation on hybrid mismatches, and Osborne reaffirmed the UK’s intention to introduce country-by-country reporting for . . .
New Zealand is considering changes to its tax laws that would tighten nonresident withholding tax rules for interest, improve the quality and usefulness of tax information provided by large corporations, address the taxation of foreign trusts, and implement OECD base erosion and profit shifting (BEPS) output, according . . .
Advancing the common consolidated corporate tax base (CCCTB) proposal in Europe is a “high priority,” for new Commissioner for Economic Affairs, Pierre Moscovici. The CCCTB would shut off major channels of tax avoidance, ensuring a closer . . .
The Swiss Federal Council on Sept. 19 initiated a consultation on rules that would extend the flat-rate credit to permanent establishments in Switzerland that are domiciled in a country that has a direct tax agreement (DTA) with Switzerland. . .
The Polish government on Sept 10 released draft general antiavoidance legislation as well as procedures for obtaining advance tax rulings to confirm that intended transactions do not qualify as abusive, write Karina Furga-Dąbrowska and Rafał Mikulski of Dentons in a Sept. 15 post. For a detailed discussion of the tax proposal, see Dentons.
The Czech Tax Administration has announced new reporting obligations applicable to companies that engage in transactions with related parties located in foreign countries, reports PwC in an August 11 newsletter. For details, see PwC.
The US Department of the Treasury’s Financial Crimes and Enforcement Network (FinCEN), on July 30, released proposed rules that would require banks and other financial institutions to learn and verify the identity of the beneficial owners of their legal entity clients . . .
The U.K. and Tajikistan signed a double tax treaty on July 1 which generally follows the OECD model tax treaty. The agreement provides for reduced withholding tax rates dividends, interest, and royalties and also includes an exchange of information article and an arbitration provision. For the text, see UK/Tajikistan Double Taxation Agreement (PDF 82K)
India’s Central Board of Direct Taxes (CBDT) and Central Board of Excise and Customs (CBEC) should immediately take steps to jointly handle tax service for large taxpayers and should aim to unify their management structures within five years, concluded a report issued by the Tax Administration Reform Commission (TARC),
The comprehensive report to newly…
Countries can legally use a multilateral instrument to amend existing bilateral tax treaties to implement the OECD’s base erosion and profit shifting (BEPS) initiative, Pascal Saint-Amans, Director, OECD Center for Tax Policy and Administration, said on May 26, during an update of OECD progress on the BEPS action plan.
Saint-Amans said that a team of international lawyers have found legal precedent in areas other than tax . . .
China will replace its turnover tax on the telecom sector with value-added tax (VAT) effective June 1, the government announced on April 30. “Basic telecom services such as voice calls and bandwidth leasing or sales will be subject to 11 percent VAT while value-added services such as messaging, data transfer and Internet access will be subject to a 6 percent rate. Telecom services for overseas clients will be exempt,” state-run news agency Xinhua reported. See, Xinhuaet
Russia’s Ministry of Finance, on March 18, published a bill introducing controlled foreign company (“CFC”) rules to the Russian tax laws. The bill also deems a foreign company as a Russian tax resident when the company’s management is in Russia and taxes sales of shares in an entity where the entity’s assets consist of indirectly owned Russian real property. For analysis, see CMS Bureau Francis Lefebvre, Laggan & Associates Ltd, Debevoise & Plimpton LLP, EY
HM Treasury and HM Revenue and Customs have released a position paper outlining the UK’s priorities for the ongoing work with G20 and OECD taking forward the 15 point Action Plan to counter Base Erosion and Profit Shifting.
The paper includes proposals for new international rules to address cross-border business structures or finance transactions, a disclosure scheme for international tax schemes, and the creation of a single Large Business Directorate within HMRC.
Even though international agreements have been reached on combating tax avoidance through the OECD/G20 base erosion profit shifting (BEPS) plan initiative, it does not necessarily follow that US multinational . . .
US presidential candidate Donald Trump’s tax plan, unveiled September 28, includes proposals for a 15 percent tax rate on all business income, limits on interest deductions and other unspecified business deductions, a deemed repatriation of all overseas profits of US multinationals at a 10 percent rate, and an end to deferral. See: Trump plan. More: TaxVox, Fortune, Slate, Bloomberg, The Guardian, CNN, New York Times, Politico, Wall Street Journal.