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OECD seeking input on digital economy taxation
Multinational Tax
Transfer pricing news, BEPS news, and international tax news relating to multinationals
Guernsey ratifies BEPS Instrument to tackle MNE tax avoidance
Guernsey BEPS MLI to enter into force in June 2019.
Armenia joins OECD’s BEPS Inclusive Framework
Armenia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
Chris Whitehouse joins Questro’s transfer pricing practice
Transfer pricing advisory Questro International has hired Chris Whitehouse as a transfer pricing partner for its Zurich office.
Ireland deposits BEPS MLI to tackle tax avoidance
For Ireland, the BEPS MLI will enter into force in May 2019.Continue Reading
Hong Kong tax authority notes CbC reporting deadline details
Hong Kong Inland Revenue Department has clarified that starting from April 2019, the Department will not accept voluntary filing of a country-by-country (CbC) report for an accounting period ended on or before March 31, 2018.Continue Reading
New Swiss-Ukraine tax treaty protocol signed
The treaty protocol provides for a low withholding tax rate of five percent for royalty and interest payments. An arbitration clause is also included to increase legal certainty for taxpayers.Continue Reading
Manuel Koch joins transfer pricing specialist Questro’s Stuttgart office
Transfer pricing specialist Questro International has hired Manuel Koch as a Partner for the firm’s office in Stuttgart, Germany.
Koch brings significant experience of over ten years specialization in transfer pricing consulting. Koch has wide experience in international tax planning engagements for international corporates including holding and principal structures as well as Swiss finance branches and IP boxes.Continue Reading
Jill Weise to lead Duff & Phelps’ transfer pricing practice
Global advisory firm Duff & Phelps has announced that Jill Weise will succeed Michael Heimert as the Global Leader for the firm’s transfer pricing practice.
Weise has nearly 25 years of expertise in transfer pricing. She previously served as the firm’s transfer pricing practice leader for North America.
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Dutch tax rulings to Nike under EU Commission’s scanner
The Commission is looking into five tax rulings issued by the Dutch tax authority to Nike group companies in the Netherlands between 2006 to 2015.Continue Reading
Indian tax authority sets new CbC reporting deadline for US subsidiaries
By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)
In India, the 2016 Finance Act introduced a three-tiered transfer pricing documentation regime with a view to aligning the Indian transfer pricing documentation rules with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.
Accordingly, Indian subsidiaries of multinational groups were required to comply with new “master” and “local” files requirements and a new country-by-country reporting requirement from the 2016-17 financial year.Continue Reading
Transfer pricing expert Mark Madrian joins Valentiam Group
Transfer pricing expert Mark Madrian has joined Valentiam Group as a Partner in the firm’s West Coast practice.
Madrian has advised clients on complex cross-border transfer pricing and other international tax issues. He was recently recognized as a Leading Transfer Pricing Adviser by Legal Media.
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Hong Kong, Finland tax treaty to take effect in April 2019
The treaty will be effective from April 1, 2019.Continue Reading
Saudi tax authority publishes draft transfer pricing bylaws
By Anas Salhieh (Senior Tax Executive, Al Tamimi & Company, Riyadh, Saudi Arabia)
Saudi Arabia’s General Authority for Zakat and Income Tax has published for public comments draft transfer pricing bylaws as part of the Kingdom of Saudi Arabia’s commitment to the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading
New EU corporate tax avoidance rules enter into force
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
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
Malta ratifies tax instrument to tackle base erosion and profit shifting
The BEPS MLI will enter into force for Malta on April 1, 2019.
Singapore Ratifies BEPS MLI to tackle MNE tax avoidance
The BEPS MLI will enter into force for Singapore on April 1, 2019.Continue Reading
Gibraltar provided illegal tax benefits to MNEs: EU Commission
Gibraltar must recover unpaid taxes of around EUR100m from companies that benefited from the corporate tax exemption regime for interest and royalties as well as from the five tax rulings.Continue Reading
Australia sees improved corporate tax compliance
In the 2015-16 income year, the estimated tax gap for large corporate taxpayers was 4.4 percent, as compared to 5.8 percent tax gap in the 2014-15 income year.Continue Reading
OECD issues second peer review report on BEPS Action 5
The OECD has made 60 jurisdiction-specific recommendations on issues such as improving the timeliness of the exchange of information and ensuring that exchanges of information are made with respect to preferential tax regimes that apply to income from intellectual property.Continue Reading
Bulgaria introduces new interest limitation and CFC regimes
By Elizabeth Sidi (Senior Tax Consultant, PwC, Bulgaria)
Bulgaria is introducing new interest limitation rules and a new controlled foreign corporation regime from January 1, 2019.
Continue ReadingIndian 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.
Continue ReadingDenmark publishes draft tax proposal to ratify BEPS MLI
The legislation is intended to enter into force in July 2019. Continue Reading
Countries need a ‘world-wide answer on tax’: IMF chief
According to IMF Chief Christine Lagarde, governments should figure out a world-wide answer on tax.Continue Reading
Cayman Islands publishes tax bill to implement substance requirements
The legislation seeks to incorporate the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project, on countering harmful tax practices, as well as the new EU substance requirements.Continue Reading
New Agreement between Ireland and Malta to counteract the ‘Single Malt’ tax structure
By Catherine O’ Meara (Partner, Matheson, Dublin) and Brian Doohan (Senior Associate, Matheson, Dublin)
On November 27, 2018, Ireland’s Finance Minister Paschal Donohoe announced the details of a Competent Authority Agreement between Ireland and Malta (Agreement). The clear aim of the Agreement is to end what is referred to as the “Single Malt” tax structure.Continue Reading
France, Germany propose new digital tax plan
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.Continue Reading
Belgium publishes draft transfer pricing guidance for public comments
By Bram Markey (Director, Transfer Pricing, PwC Belgium)
The Belgian tax authority has issued a draft Circular on the 2017 update to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.Continue Reading
