On November 22, 2023, the Swiss Federal Council adopted the dispatch on the approval and implementation of an additional agreement supplementing the country’s tax treaty with France.
A review petition has been filed in the controversial most-favored-nation (MFN) judgment delivered by the Indian Supreme Court last month.
Spain has been awarded for taking the shortest time in closing transfer pricing cases under the mutual agreement procedure (MAP) set out in tax treaties.
The 2021 MAP Statistics were presented during the OECD Tax Certainty Day, where tax officials and stakeholders took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution. The MAP Award is given in recognition of efforts by competent authorities in dealing with MAP cases.
The suspension will continue the beginning of September 2021.
The G7 (which includes the UK, the US, Canada, Japan, Germany, France, Italy, plus the EU) agreed the principles of an ambitious two Pillar global solution to tackle the tax challenges arising from an increasingly globalized and digital global economy.
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.
Janet Yellen, who took oath as the 78th Secretary of the US Department of the Treasury on January 26, held a discussion with counterparts in France, Germany and the UK on digital economy taxation.
The US Trade Representative said that it has decided to suspend the tariffs in light of the ongoing investigation of similar DSTs adopted or under consideration in ten other jurisdictions.
Gurría was responding to recent statements and exchanges regarding the ongoing negotiations to address the tax challenges of the digitalisation of the economy.
French Finance Minister, Bruno Le Maire, termed the US’ proposed action as unacceptable.
Earlier in July 2019, the US Trade Representative opened an investigation into whether the French DST is discriminatory in nature and harms US’ interests.
Comments must be received by December 2.
The new anti-abuse measures entered into force on January 1, 2019.
Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.
Qatar is the 85th jurisdiction to sign the BEPS Convention, which now covers nearly 1,500 bilateral tax treaties.
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.
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.
On December 29, 2017, the Italian Government published Law No. 205 of December 27, 2017 (Budget Law) in the Italian Official Journal, which contains key tax measures including a new tax on digital transactions (Web Tax) and revisions to the definition of permanent establishment (PE) in the domestic law.
By Terence WILHELM (Attorney at Law, Managing Partner, CARA Avocats, France)
On December 31, 2017, the French Government gazetted Finance Act, 2018, which revises the current transfer pricing documentation requirements in France. Accordingly, companies falling within the ambit of the new requirements will need to newly submit to the tax authority a two-fold documentation comprising “master” and “local” files, developed under Action 13 of the OECD’s base erosion and profit shifting (BEPS) project. The revised transfer pricing documentation requirement is inserted in Article L13AA of the French Procedural Tax Book (Livre des procedures fiscales) and is applicable to fiscal years beginning January 1, 2018.
On January 15, 2018, the Government of Hong Kong announced that it has entered into a bilateral arrangement with France to automatically exchange country-by-country (CbC) reports filed by multinational corporations.