Australia wins first diverted profits tax case against Pepsi

The Australian Taxation Office (ATO) has won a court case that, for the first time, considered the diverted profits tax – a new tool to ensure multinationals pay the right amount of tax.Continue Reading

Australian thin capitalization tax bill flawed: CA ANZ

Australia’s Treasury Laws Amendment (Making Multinationals Pay Their Fair Share – Integrity and Transparency) Bill 2023, which includes thin capitalization measures, is flawed in several respects, Chartered Accountants Australia & New Zealand (CA ANZ) has said.Continue Reading

OECD publishes guidance on global minimum corporate tax rules

OECD publishes guidance on global minimum corporate tax rules

The OECD, on February 2, released technical guidance to assist governments with implementation of the 15 percent global minimum corporate tax rate.Continue Reading

Netherlands opposes UN international tax framework

Netherlands warns against UN international tax cooperation framework

The Dutch State Secretary of Finance, Marnix van Rij, has expressed the government’s concerns regarding the recent UN resolution to establish an international tax cooperation framework.Continue Reading

Australia expanding tax treaty network

Australia expanding tax treaty network

The Australian government is expanding its tax treaty network to provide improved certainty to taxpayers and guard against tax avoidance practices.

New negotiations are planned with Bulgaria, Colombia, Croatia, Cyprus, Estonia, Latvia, and Lithuania. These countries add to the current program which includes Portugal, Slovenia, Greece, and Luxembourg.Continue Reading

Australia gets over AUD 68 billion in corporate income tax

Australia gets over AUD 68 billion in corporate income tax

This year’s report represents 2,468 corporate entities, who paid a combined AUD 68.6 billion in income tax, AUD 11.4 billion or 19.8 percent more than the previous year and the highest since reporting began.Continue Reading

Glencore’s transfer pricing tax victory: key takeaways

By Carmen McElwain (Partner, Minter Ellison, Melbourne, Australia)

On 21 May 2021 the High Court of Australia (comprised of Chief Justice Kiefel and Justice Gordon) heard and refused an application for special leave sought by the Commissioner of Taxation (Commissioner) in relation to the Full Federal Court’s decision in Commissioner of Taxation v Glencore Investments Pty Ltd (2020) [2020] FCAFC 187; 384 ALR 252 (Glencore). Continue Reading

Global minimum corporate tax rate should be 15 percent: US Treasury

Global minimum corporate tax rate should be 15 percent

The US Treasury expressed its belief that the international tax architecture must be stabilized, that the global playing field must be fair, and that we must create an environment in which countries work together to maintain our tax bases and ensure the global tax system is equitable.Continue Reading

OECD releases new MAP peer review reports

The reports evaluate the progress made by these eight jurisdictions in implementing any recommendations resulting from their stage 1 peer review. They take into account any developments in the period January 2018- August 2019 and build on the MAP statistics for 2016-2018.Continue Reading

Australia expanding ‘significant global entity’ definition

Australia expanding ‘significant global entity’ definition

The definition of “significant global entity” to include members of large business groups headed by private companies, trusts, partnerships, investment entities, and individuals.Continue Reading

BEPS MLI to enter into force in Australia in January 2019

BEPS MLI to enter into force in Australia in January 2019
From January 1, 2019, the BEPS MLI will operate to modify six of Australia’s 44 bilateral tax treaties. These include tax treaties with France, Japan, New Zealand, Poland, the Slovak Republic, and the UK.Continue Reading

Indian tax authority undergoing ratification process for BEPS MLI

Indian tax authority undergoing ratification process for BEPS MLI

Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.

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BDO Melbourne Gets New Tax Partner in Michael Smith

Michael Smith has joined BDO Melbourne’s transfer pricing team as a partner.

Smith has nearly 20 years’ of transfer pricing experience from around the world. He has worked in London, New York, and Sydney.   Continue Reading

OECD’s Work on Harmful Tax Practices on Track

OECD’s Work on Harmful Tax Practices on Track

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The OECD has published a report covering the assessment of 53 preferential tax regimes as part of its work under base erosion and profit shifting (BEPS) Action 5, on harmful tax practices.
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Australian Taxation Office, BHP Settle Transfer Pricing Dispute

Australian Taxation Office, BHP Settle Transfer Pricing Dispute

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Australian tax authority has settled a transfer pricing dispute with BHP in relation to the mining giant’s marketing operations in Singapore.
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Mutual Agreement Procedure Statistics Published for 2017

Mutual Agreement Procedure Statistics Published for 2017

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

Australia Seeking Input on Digital Economy Taxation

Australia Seeking Input on Digital Economy Taxation

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


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

More Countries Ratify BEPS Convention

More Countries Ratify BEPS Convention

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

Hybrid Mismatch Rules Enacted in Australia

Hybrid Mismatch Rules Enacted in Australia

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Treasury Laws Amendment (Tax Integrity and Other Measures No.2) Act, 2018 – which gives effect to the OECD Hybrid mismatch rules in Australia – received Royal Assent on August 24.Continue Reading

MAP Peer Review Reports Out for Australia, Ireland, Japan, Five Others

MAP Peer Review Reports Out for Australia, Ireland, Japan, Five Others

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The OECD on August 30 published stage 1 mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal.Continue Reading

MNE Tax Avoidance Law a ‘Major Victory’ for Australia

MNE Tax Avoidance Law a ‘Major Victory’ for Australia

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


Over 40 multinational enterprises (MNEs) have restructured their business operations in response to Australia’s crack down on MNE tax avoidance law, ATO Deputy Commissioner Mark Konza has said.Continue Reading

Australia Passes Law to Give Force to BEPS Convention

Australia Passes Law to Give Force to BEPS Convention

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Australian Parliament on August 16 passed a legislation to give the force of law to the OECD’s Multilateral Convention to implement tax treaty-related measures to tackle base erosion and profit shifting (BEPS).Continue Reading

Australian Taxation Office Issues Draft Guidance on Related Party Financing Arrangements

Australian Taxation Office Issues Draft Guidance on Related Party Financing Arrangements

The Australian Taxation Office (ATO) has published for public comments Schedule 2 to Practical Compliance Guideline (PCG) 2017/4DC, which discusses the tax authority’s  compliance approach to tax issues relating to cross-border, related-party financing arrangements and related transactions.Continue Reading

Tax Bill Seeks to Improve Australia’s Thin Capitalization Regime

Tax Bill Seeks to Improve Australia’s Thin Capitalization Regime

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Australian Treasury has published for comments a draft tax Bill that would implement two key changes to improve the country’s thin capitalization regime. The changes – first proposed in the 2018-19 Budget – are intended to apply from income years beginning on July 1, 2019.Continue Reading

Australia Revising ‘Significant Global Entity’ Definition

Australia Revising ‘Significant Global Entity’ Definition

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Australian Government is consulting stakeholders on a law that would extend the definition of a “significant global entity” to ensure multinational tax laws apply uniformly to all relevant entities.Continue Reading

Baker McKenzie Elects New Tax Partners

Law firm Baker McKenzie has announced the election of 13 new tax partners.

The newly elected partners are: Michael Nixon (Singapore), Simone Bridges (Sydney), Kirill Vikulov (Moscow), David Jamieson (London), Jessica Eden (London), Rodrigo Castillo Cottin (Bogota), Paul F. DePasquale (New York), Tatyana Johnson (New York), Victor Alejandro Morales-Chavez (Mexico City), Jonathan Welbel (Chicago), Joshua Nixt (New York), Andrew C. O’Brien-Penney (Chicago), and Ivan Tsios (Chicago).Continue Reading

ATO Issues Draft Tax Guidance on Hybrid Mismatch Rules

ATO Issues Draft Tax Guidance on Hybrid Mismatch Rules

On June 21, 2018, the Australian Taxation Office (ATO) published for stakeholders’ comments draft Practical Compliance Guideline (PCG 2018/D4) to assist taxpayers who may be affected by the country’s hybrid mismatch rules and wish to unwind or restructure out of existing hybrid arrangements.Continue Reading

Australia Consulting on Draft Hybrid Mismatch Tax Rules

Australia Consulting on Draft Hybrid Mismatch Tax Rules

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


On March 8, 2018, the Australian Government released for public comments revised exposure draft legislation aimed at tackling hybrid mismatch arrangements.Continue Reading

Australia to Retrospectively Amend MAAL

Australian Government publishes draft Bill, which would retrospectively amend the Multinational Anti-Avoidance Law (MAAL)

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


On February 12, 2018, the Australian Government published for stakeholders’ comments a draft Bill, which would retrospectively amend the Multinational Anti-Avoidance Law (MAAL) to prevent multinationals from avoiding the application of the MAAL through the use of foreign trusts and partnerships in corporate structures.Continue Reading

Australia Consulting on Draft Legislation to Implement BEPS Convention

The Australian Government today published for stakeholders’ comments a draft legislation to implement the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures in Australia.

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


The Australian Government today published for stakeholders’ comments a draft legislation to implement the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures in Australia.Continue Reading

UK, US, Six Others Launch Multilateral Tax Risk Assurance Program For MNEs

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 


Eight tax administrations, including the UK and the US, have launched a pilot program for the multilateral risk assessment of multinational corporations.Continue Reading