The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading
The Australian Taxation Office has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes.Continue Reading
The tax treaty between Japan and Iceland will enter into force on October 31, 2018, Japan’s Finance Ministry has announced.Continue Reading
The Australian Government on October 2 launched for public comments a consultation document aimed at creating a fairer and more sustainable corporate tax system for the digitalized economy.Continue Reading
Senior tax officials from over 20 countries recently met at a workshop to share experiences from the first year of country-by-country (CbC) reporting and explore how information can be used most effectively in the tax risk assessment of MNE groups.Continue Reading
Australia, France, Japan, and the Slovak Republic have deposited their instruments of ratification of the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).
For these four countries, the BEPS Convention would enter into force from January 1, 2019. The Convention entered into force last month for New Zealand, Serbia, Sweden, and the UK.Continue Reading
Japan on September 26 deposited to the OECD the instrument of acceptance of the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.
The BEPS Convention will enter into force for Japan on January 1, 2019.Continue Reading
By Adv. (Eco.) Eyal Bar-Zvi (Partner and Head of Transfer Pricing, Herzog Fox & Neeman)
The Israel Tax Authority, on September 5, 2018, published two safe harbor Circulars (which remained in draft mode for several months), noting the tax authority’s expected profit levels for marketing services and for low-risk distributorship activities carried out in Israel by multinational entities (MNEs), and providing guidance on non-value-added services.Continue Reading
Saudi Arabia has become the 84th tax jurisdiction to sign the base erosion and profit shifting (BEPS) Multilateral Convention.
The BEPS Convention, negotiated by over 100 countries and jurisdictions, updates the existing network of 1,400 bilateral tax treaties and reduces opportunities for tax avoidance by multinational enterprises.Continue Reading
The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa, and Turkey. The OECD has also updated the information contained in Singapore’s profile.Continue Reading