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OECD officials discuss international tax and transfer pricing agenda
Tax officials provided an update on international tax and transfer pricing work underway at the OECD Centre for Tax Policy and Administration during an OECD Tax Talks webinar, held October 16. This latest webinar covered a range of topics, including OECD efforts to facilitate global agreement on . . .
Google India’s payments to Google Ireland for AdWords program are royalties subject to withholding tax, court rules
An Indian appellate court has ruled that payments made by Google’s Indian subsidiary to Google’s Irish subsidiary to operate the Google AdWords program in India were royalties subject to withholding tax and not payments to obtain advertising space for resale, as Google has claimed. The court also mandated the use of the profit split method for some related-party transactions. . .
US IRS reassessing transfer pricing strategy following court losses, unable to sign all country-by-country reporting CAAs
US IRS and Treasury officials joined tax practitioners and corporate tax executives today to discuss key international tax and transfer pricing developments at the 30th Annual Institute on Current Issues in International Taxation, cosponsored by George Washington University Law School and the Internal Revenue . . .
EU doubles down on State aid theory, orders Amazon to pay Luxembourg taxes
Dimitrios Kyriazis of the New College of the Humanities and University of Oxford discusses today’s news that the EU Commission has adopted a negative decision in the Amazon fiscal State aid case and the Commission’s argument that a departure from the arm’s length principle amounts to the conferral of an advantage to the recipient . . .
New ‘toolkit’ addresses lack of transfer pricing comparables
The “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and the World Bank – today published the final version of a toolkit designed to provide developing . . .
Hong Kong, Indonesia agree to automatic exchange for tax purposes
Hong Kong and Indonesia have agreed to automatic exchange of financial account information in tax matters (AEOI), a Hong Kong . . .
Italian law aims to encourage foreign internet companies to pay more tax
Italian legislation proposed May 22 is designed to increase tax collection from foreign multinationals that have online activities Italy, writes Davide Anghileri of the University of Lausanne . . .
EU court rules company reps may face criminal liability for corporation’s failure to pay tax
The European Court of Justice (ECJ) has ruled that a criminal proceeding can be brought against the legal representative of a company even if the company has already paid a tax penalty with respect to the same act or omission, writes Davide Anghileri of the University of Lausanne . . .
OECD officials provide update on international tax agenda
Tax officials, during a March 28 webcast, discussed the OECD’s international tax agenda, including plans to release tax and transfer pricing guidance and promote . . .
Italy publishes tax rules implementing country-by-country reporting for large multinationals
Davide Anghileri of the University of Lausanne discusses Italy’s new country-by-country reporting requirements for large multinationals . . .