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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Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

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 at editor@transferpricingnews.com  


Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta.
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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

Ireland Consulting on Corporate Anti-Tax Avoidance Measures

Ireland Consulting on Corporate Anti-Tax Avoidance Measures

On November 14, 2018, Ireland’s Department of Finance published for public comments a consultation document on the hybrid mismatch and interest limitation measures to be introduced as part of the implementation of the EU Anti-Tax Avoidance Directives (ATAD and ATAD2).
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UK Announces 2% Digital Services Tax From 2020

UK Announces 2% Digital Service Tax From 2020

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). 


UK would introduce a two percent digital services tax (DST) to ensure digital businesses pay tax that reflects the value they derive from UK users, UK Chancellor Philip Hammond announced in his October 29 Budget Speech.Continue Reading

Ireland Signs Order to Ratify BEPS Convention

Ireland Signs Order to Ratify 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). 


Ireland’s Government has signed an Order to facilitate ratification of the OECD’s Multilateral Instrument to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).Continue Reading

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

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

EU Commission to Drop Infringement Proceedings in Ireland-Apple State Aid Decision

EU Commission to Drop Infringement Proceedings in Ireland-Apple State Aid Decision

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 EU Commission is now to withdraw infringement proceedings against Ireland as the Government has now completed full recovery of the alleged State aid from Apple.Continue Reading

Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law

Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law

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). 


Ireland’s Finance Minister Paschal Donohoe has published the country’s Corporation Tax Roadmap outlining the steps that the Government will take in the area of international tax law over the next few years.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

UK Raises £388 million from Diverted Profits Tax Law in 2017-18

UK Raises £388 million from Diverted Profits Tax Law in 2017-18

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 UK tax authority, HM Revenue and Customs (HMRC), raised GBP388m from the diverted profits tax (DPT) legislation in 2017-18, according to the Transfer Pricing and Diverted Profits Tax Statistics published on July 31.Continue Reading

New Mexican Transfer Pricing Adjustment Regulations Explained

New Mexican Transfer Pricing Adjustment Regulations Explained

By Guillermo Villaseñor-Tadeo (Partner, Sánchez Devanny, Mexico) and Pedro Palma-Cruz (Attorney, Sánchez Devanny, Mexico)

Mexico’s Tax Administration Service on July 11, 2018, updated the country’s existing regulations concerning transfer pricing adjustments as set out in rules 3.9.1.1 to 3.9.1.5 of the Resolución Miscelánea Fiscal. The changes are aimed at clarifying many questions that arose from the enactment of the first set of regulations on transfer pricing adjustments last year. In broad terms, the regulations can be classified as: definition and types, application, requirements, and timing issues and deadlines. These are discussed below.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

UK to Amend Corporate Interest Restriction Rules

UK to Amend Corporate Interest Restriction 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). 


The UK Government has published draft legislation that would make technical amendments to the country’s corporate interest restriction rules to ensure the corporation tax regime works as intended.Continue Reading

Guernsey Signs New Tax Treaty With UK

Guernsey Signs New Tax Treaty With UK

Guernsey has signed a new tax treaty with the UK. The new tax treaty replaces the one that has been in force since 1951.

The new tax treaty is based, broadly, on the OECD Model Tax Convention, which Guernsey has generally followed in its negotiations with other jurisdictions in recent years. The text of the tax treaty incorporates some of the recent international standards designed to prevent base erosion and profit shifting (BEPS). Continue Reading

UK Publishes Tax Guidance on MAP Framework

UK Publishes Tax Guidance on MAP Framework

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 20, 2018, the UK Government published “Statement of Practice 1 (2018)” on the country’s mutual agreement procedure (MAP) framework. The Statement supersedes “Statement of Practice 1 (2011).”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

UK ‘Brought In’ Over GBP8bn from Large Companies in 2016-17

UK Corporate Tax

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). 


Mel Stride, Financial Secretary to the UK Treasury, has said that the Government has brought in and protected more than GBP8bn in 2016-17 from UK’s largest companies.Continue Reading