Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.
Continue ReadingIndian tax authority undergoing ratification process for BEPS MLI
Featured-News
Transfer pricing news, BEPS news, and international tax news from around the world.
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
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
Mauritius tax authority issues guidance on place of effective management
The majority of the Board of Directors’ meetings must be held in Mauritius, or the executive management of the company must be regularly exercised in Mauritius.
Netherlands to Deny Tax Rulings to ‘Letterbox’ Companies
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
Netherlands will be putting into place stricter requirements for the issue of international tax rulings by the end of June 2019.
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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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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
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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Barbados to Align Tax Regime with BEPS Proposals from December 2018
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).
Barbados Cabinet has decided to put in place new measures to ensure that the country’s tax regime is compliant with the OECD’s base erosion and profit shifting (BEPS) recommendations, Minister of International Business and Industry, Ronald Toppin, said on November 15.
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Hong Kong Gazettes Enhanced R&D Deduction
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).
Hong Kong Government has gazetted law to allow enhanced tax deduction for expenses incurred by business enterprises on research and development (R&D) activities in Hong Kong.
The measure was announced by Carrie Lam, Chief Executive of Hong Kong, in her 2017 Policy Address.Continue Reading
UK Announces 2% Digital Services 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
Global Solution Needed to Tax Digital Economy: Policy Paper
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 US-based Association of International Certified Professional Accountants has called for international coordination to develop a global solution to the tax challenges posed by the digital economy.Continue Reading
Ukraine Publishes Draft Tax Law to Implement BEPS Proposals
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).
Ukraine has published a draft law aimed at implementing some of key measures proposed under the OECD’s base erosion and profit shifting (BEPS) project.
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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
EU Digital Services Tax Proposal ‘Unfair’: US Treasury Secretary
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).
US Treasury Secretary Steven Mnuchin has issued a statement noting “strong” concerns with countries’ consideration of a digital services tax proposal.
In March 2018, the EU Commission announced it proposal to introduce an interim tax, which would cover the main digital activities that currently escape tax altogether in the EU.Continue Reading
Abandon Digital Services Tax Proposal: US Tells EU
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 US Senate Committee on Finance has asked the European Commission to “abandon” its proposal to introduce a three percent digital services tax on revenues arising from the supply of certain digital services.Continue Reading
Ireland Finance Bill 2018 to Include International Tax Measures
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 would introduce key international tax measures in Finance Bill 2018 to comply with the EU Anti-Tax Avoidance Directive, Finance Minister Paschal Donohoe said in his 2019 Budget Statement released on October 9. The Finance Bill 2018 is due to be published on October 18.Continue Reading
Norway’s Budget 2019 Includes BEPS Measures
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 Norwegian Government on October 8 presented the country’s National Budget 2019, which includes a series of measures to tackle base erosion and profit shifting (BEPS).Continue Reading
New Zealand Reveals Details of New R&D Tax Incentive
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).
New Zealand Government has revealed details about the new research and development (R&D) tax incentive aimed at encouraging businesses to invest more in R&D activities.
The rate for the tax incentive will be set at 15 percent for income years starting 2019-20. All businesses, regardless of legal structure, will be eligible to claim the tax incentive.Continue Reading
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
Cameco Wins Transfer Pricing Tax 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 Tax Court of Canada has ruled in favour of leading uranium miner Cameco in a CAD2.2bn transfer pricing dispute with the Canada Revenue Agency (CRA).
Cameco had disputed reassessments issued by CRA for the 2003, 2005, and 2006 tax years.Continue Reading
BEPS Convention to Enter into Force in Japan from January 2019
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).
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
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
No Sweet Tax Deal between Luxembourg, McDonald’s: EU Commission
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 on September 19 decided that Luxembourg’s tax treatment of McDonald’s Europe Franchising does not violate the Luxembourg-US tax treaty and that tax rulings granted to McDonald’s do not infringe EU State aid rules.
The decision follows an in-depth investigation launched in December 2015, based on doubts that Luxembourg might have misapplied its tax treaty with the US.Continue Reading
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
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
India Concluding More Bilateral Advance Pricing Agreements
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 Indian tax authority, Central Board of Direct Taxes, has published its second annual report on advance pricing agreement (APA) highlighting the progress made in 2017-18.Continue Reading
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
New Zealand Issues Draft BEPS Guidance
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).
New Zealand Inland Revenue is seeking public input on draft tax guidance aimed at helping businesses comply with the Taxation (Neutralising Base Erosion and Profit Shifting) Act, which was enacted earlier this year.Continue Reading
Switzerland Adopts Dispatch on 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 Swiss Federal Council on Wednesday adopted the dispatch on the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading
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
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
Country by Country Reporting Guidance Updated in Bermuda
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 Government of Bermuda has issued an updated tax guidance to assist businesses on complying with Bermuda’s country-by-country (CbC) reporting requirement.Continue Reading
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
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
Malaysia Revising Tax Rules to Adopt BEPS Action 5 Minimum Standard
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 Government of Malaysia has said that it will not grant new approvals to companies in respect of tax incentives provided under MSC Malaysia Bill of Guarantee No.5.Continue Reading
MNE Tax Avoidance Thing of the Past, OECD Tells G-20
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).
Multinational enterprises (MNEs) are “changing their behavior” as a direct result of recent tax measures taken to tackle base erosion and profit shifting (BEPS), the OECD has told the Group of Twenty (G-20) Finance Ministers.Continue Reading
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
OECD Briefs G-20 on BEPS Implementation
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 progress report setting out the major tax developments that took place in the last year concerning the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading
BusinessEurope Calls for Global Agreement 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 Confederation of European Business (BusinessEurope) has said that a global agreement is needed on changes to international tax rules concerning the digital economy to ensure a global level-playing field encompassing all major tax jurisdictions.Continue Reading
US Tax Authority Issues Final Inversion Regulations
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 US Internal Revenue Service (IRS) has issued final regulations on inversions and related transactions.
The final regulations – issued on July 12 – address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code and certain post-inversion tax avoidance transactions.Continue Reading
EU Committee Calls For Fair, Uniform Taxation of Digital Economy
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 European Economic and Social Committee (EESC) has called for a fair, consensus-based international solution at the OECD-level to tackle tax challenges posed by the digital economy.
The EU advisory body said that contrary to common international corporate taxation practice, the European Commission’s proposals aims to tax businesses’ turnover instead of profits, and to levy taxes where sales take place instead of where value is created. This approach, it noted, could jeopardize the integrity of the EU single market and lead to double taxation.Continue Reading
Hong Kong Implements BEPS Minimum Standards
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 Hong Kong Government today gazetted the Inland Revenue (Amendment) (No.6) Ordinance 2018, to implement the minimum standards agreed under the base erosion and profit shifting (BEPS) project and to codify the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112).Continue Reading
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
Selective Tax Advantage to Starbucks: EU Court Hears the Netherlands
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).
At a hearing of the General Court of the European Union on July 2, the Dutch Government put forward three points to demonstrate that it did not provide selective tax advantages to Starbucks in violation of the EU state aid rules.Continue Reading
Further Three Tax Jurisdictions Sign 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).
Kazakhstan, Peru, and the UAE have signed the base erosion and profit shifting (BEPS) Multilateral Convention, the OECD has announced, adding that Estonia intends to sign the Convention on June 29.Continue Reading
New Zealand Finalizes MNE Tax Avoidance 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).
A bill aimed at tackling multinational tax avoidance will come into force on July 1, 2018, New Zealand’s Revenue Minister, Stuart Nash, has announced.Continue Reading
New OECD Guidance on Hard-to-value Intangibles, Profit Split Method
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 June 21, 2018, the OECD released two reports setting out key guidance on the application of the approach to hard-to-value intangibles, and on the application of the transactional profit split method, as part of its work on base erosion and profit shifting (BEPS) project.Continue Reading
Switzerland to Exchange 109 CbC Reports With 35 nations
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 Swiss Federal Tax Administration (FTA) will exchange this month 109 country-by-country (CbC) reports of multinational enterprises’ (MNEs) with 35 foreign tax jurisdictions.Continue Reading
2017 Update to UN Tax Convention Released
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 United Nations has published the 2017 update to the UN Model Tax Convention, which incorporates changes agreed as part of the base erosion and profit shifting (BEPS) project.Continue Reading
OECD Report Card on CbC Reporting Implementation Out
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).
60 out of 90 countries have introduced tax legislation to implement country-by-country (CbC) reporting obligation for multinational enterprises (MNEs), in line with Action 13 of the base erosion and profit shifting (BEPS) project, according to a May 24 OECD report.Continue Reading
BEPS Convention to Enter Into Force in July
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’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS) will enter into force on July 1, 2018.Continue Reading
Countries Agree to Reach Consensus on Digital Taxation by 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).
The OECD on March 16 released its Interim Report on the Tax Challenges Arising from Digitalisation, noting a lack of consensus among countries on either the merit or the need for interim measures to address the tax challenges posed by the digital economy.Continue Reading
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
MNEs Using Irish, Dutch Tax Systems to Avoid Tax: Commission Report
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).
In a first, the European Commission has stressed that tax rules in seven EU member states facilitate corporate tax avoidance by multinational enterprises (MNEs).Continue Reading
Ireland’s FM Discusses Corporate Tax Rate, US Tax Reform
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).
In his recent address to the Irish Tax Institute, Ireland’s Finance Minister, Paschal Donohoe, outlined views on critical tax issues such as the country’s low corporate tax rate, the impact of US tax reforms, and digital taxation.Continue Reading
Netherlands Underlines Plan to Tackle Tax Avoidance
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).
In a 24-page long letter to the country’s Parliament, Dutch State Secretary for Finance, Menno Snel, has set out a detailed tax plan to tackle multinational tax avoidance, including measures to prevent the internationally-oriented Dutch tax system from being used as a conduit to tax havens.Continue Reading
Brazil to Revisit Transfer Pricing 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 OECD is working with Brazil to examine the similarities and gaps between the Brazilian and OECD approaches to valuing related-party, cross-border transactions for tax purposes.Continue Reading
EC Publishes Non-confidential Version of Luxembourg-Amazon 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).
On February 26, 2018, the European Commission published the non-confidential version of its decision concluding that Luxembourg granted undue tax benefits worth around EUR250m to Amazon.Continue Reading
EU Digital Tax ‘Ship’ Has Sailed: Commissioner Moscovici
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).
Europe is determined to introduce key changes to the EU corporate tax framework to address the tax challenges posed by the digital economy, EU Tax Commissioner Pierre Moscovici has said.Continue Reading
Singapore Updates Transfer Pricing Guidance
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 23, 2018, the Inland Revenue Authority of Singapore (IRAS) published key updates and amendments to the country’s transfer pricing guidelines, including new transfer pricing documentation requirements.Continue Reading
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
Australia to Retrospectively Amend 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
US Tax Authority Increases APA User Fees
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 US Internal Revenue Service (IRS) has increased user fees for advance pricing agreement (APA) requests filed from July 1, 2018, with a further increase from January 1, 2019.Continue Reading
Norway Publishes Taxpayer 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 7, 2018, the Norwegian Government published detailed taxpayer guidance on the mutual agreement procedure (MAP) framework set out in Norway’s tax treaties.Continue Reading
OECD Issues Further CbC Guidance, Updates Preferential Regime Reviews
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 today released additional guidance for tax administrations and multinational corporations on the implementation of country-by-country (CbC) reporting requirement.Continue Reading
Australia Consulting on Draft Legislation to Implement 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 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
Legislative Proposal on EU Rules on Digital Economy Taxation Likely in March 2018
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 European Commission is likely to table a legislative proposal on EU rules on taxation of profits of multinational corporations in the digital economy by March 2018.Continue Reading
Indian 2018 Budget Introduces Virtual PE Concept to Tax Business Profits
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 1, 2018, India’s Finance Minister, Arun Jaitley, issued the country’s 2018 Budget, which introduces a new permanent establishment (PE) nexus based on virtual economic presence to tax business profits of foreign enterprises.Continue Reading
Google Happy to Pay More Taxes: Sundar Pichai
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).
Google is happy to pay a higher amount of tax, Sundar Pichai, chief executive officer of Google Inc, has said.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
Panama, Malaysia, Four Others Sign OECD’s 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).
Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama, and Tunisia have newly signed the base erosion and profit shifting (BEPS) Multilateral Convention, the OECD announced on January 24, 2018.Continue Reading
Panama, Others Removed from EU’s List of Non-cooperative Tax Jurisdictions
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).
Following commitments made at a high political level to remedy EU concerns, the Council of the European Union, on January 23, 2018, removed eight tax jurisdictions, including Panama, from the EU list of non-cooperative jurisdictions for tax purposes.
UK ‘Brought In’ Over GBP8bn from Large Companies in 2016-17
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
US IRS Issues Five New Transfer Pricing Directives
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 January 16, 2018, the US Internal Revenue Service published five new tax directives, which provide instructions to Large Business & International (LB&I) examiners on key transfer pricing matters.Continue Reading
New South Africa Tax Guidance on Prohibition of Deductions for “Tainted” IP
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 South African Revenue Service has issued detailed guidance on the interpretation and application of section 23I of the Income Tax (IT) Act, which relates to the prohibition of deductions for “tainted” intellectual property (IP).Continue Reading
Malaysian Tax Authority Issues Taxpayer Guidance On MAP
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 January 11, 2018, the Inland Revenue Board of Malaysia released detailed taxpayer guidance on the mutual agreement procedure (MAP) framework contained in tax treaties.Continue Reading
Hong Kong Implements Country-by-Country Reporting Requirement
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 December 29, 2017, Hong Kong gazetted the Inland Revenue (Amendment) (No. 6) Bill, 2017, which provides for an implementation framework for country-by-country (CbC) reporting in Hong Kong.Continue Reading
Hong Kong Gazettes Transfer Pricing Changes
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 December 29, 2017, Hong Kong gazetted the Inland Revenue (Amendment) (No. 6) Bill, 2017, which codifies transfer pricing principles into the Inland Revenue Ordinance (Cap. 112) and implements the OECD’s BEPS minimum standards.Continue Reading
2017 Update to OECD Model Tax Convention Released
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 December 18, 2017, the OECD released the 2017 edition of the OECD Model Tax Convention, which incorporates significant changes developed under BEPS project.Continue Reading
Over 1,400 automatic exchange relationships in place
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).
There are now over 1,400 automatic exchange relationships in place among tax administrations committed to exchanging country-by-country (CbC) reports as of mid-2018.Continue Reading
