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
Featured-News
Transfer pricing news, BEPS news, and international tax news from around the world.
Indian Supreme Court urged to review MFN tax ruling
A review petition has been filed in the controversial most-favored-nation (MFN) judgment delivered by the Indian Supreme Court last month.Continue Reading
Barbados to levy 9% corporate tax, adopt global minimum tax
Barbados will levy an increased corporate tax rate of nine percent for most corporations from January 2024.Continue Reading
New Zealand will bring digital services tax if global agreement fails
New Zealand will implement a digital services tax in 2025 if international agreement on the issue fails to pass through, Finance Minister Grant Robertson has said.Continue Reading
Indonesia calls global minimum tax a ‘trick’ by developed nations
Indonesia’s Minister of Investment has dismissed the global minimum tax proposal as a self-serving ‘trick’ being pulled by developed nations.Continue Reading
UK tax advisers hail transfer pricing, diverted profits tax reform
The Chartered Institute of Taxation (CIOT) has welcomed proposed reforms to the UK legislation on transfer pricing, permanent establishments, and diverted profits tax.Continue Reading
Legal challenge to EU directive on global minimum tax dismissed
The General Court of the European Union has dismissed a legal challenge to EU Directive 2022/2523 of 14 December 2022, on ensuring a global minimum taxation for multinational enterprise (MNE) groups.Continue Reading
Australia asks MNEs for views on global minimum tax rules
Australia is inviting multinational enterprises (MNEs) to share their views on the implementation of the global minimum tax rules.Continue Reading
Bermuda to levy corporate tax on MNEs from 2025
Bermuda is consulting stakeholders on a new corporate tax regime from 2025 in view of the OECD’s proposed global minimum tax rules.Continue Reading
Australia to strength tax rules on tax adviser misconduct
Australian government has announced a slew of tax reform measures aimed at tackling tax adviser misconduct in the wake of the PwC tax leaks matter.Continue Reading
Canada publishes draft Global Minimum Tax Act, DST bill
Canada’s government is seeking public input on draft tax legislation to implement a global minimum corporate tax rate, commonly known as GloBE, approved by the OECD’s Inclusive Framework.Continue Reading
South Africa publishes draft tax law on advance pricing agreement
The South African Revenue Service is seeking stakeholders’ comments on a draft tax law implementing a new advance pricing agreement (APA) program.Continue Reading
Slovakia publishes draft law on global minimum tax
Slovakia’s Finance Ministry is seeking public input on draft tax law aimed at implementing a 15 percent global minimum corporate tax rate.Continue Reading
Luxembourg approves draft tax bill on global minimum tax
On 28 July 2023, the Luxembourg Council of Ministers adopted a bill transposing the EU Directive on global minimum tax into the country’s domestic tax law.Continue Reading
Vietnam looking to implement global minimum tax
Vietnamese government will submit its policy on global minimum tax to the National Assembly in October this year.Continue Reading
OECD develops tax instruments to tackle tax avoidance in West Africa
The OECD has developed three tax instruments to strengthen the fight against base erosion and profit shifting (BEPS) in West Africa.Continue Reading
Gibraltar to implement global minimum tax from 2025
Gibraltar is seeking to implement a new tax regime for companies within the scope of OECD’s proposed Pillar Two tax rules, and a domestic minimum top-up tax, Chief Minister Fabian Picardo said while delivering the draft Budget for 2023-24.Continue Reading
138 tax jurisdictions agree on global tax reform, defer digital tax measures
138 tax jurisdictions have agreed an ‘Outcome Statement” on ways to move forward with historic, major reform of the international tax system.Continue Reading
Extend standstill on digital services tax: EU companies tell OECD
EU digital companies have written to the OECD asking it to extend the standstill agreement on digital services tax.Continue Reading
OECD denies claims it diluted Australian tax transparency bill
The OECD has rubbished media claims that it pressured Australian government into weakening the country’s tax bill aimed at tackling tax avoidance.Continue Reading
Brazil consulting on new transfer pricing tax regulations
Brazil’s Special Secretariat of the Federal Revenue is consulting stakeholders on a draft Normative Instruction that would regulate the country’s new transfer pricing regime.Continue Reading
In Obama’s blacklist once, but leading fight against tax avoidance today: Dutch tax official
Netherlands may have been on Obama’s blacklist in 2009, but it now leads the fight against tax avoidance, Marnix van Rij, Dutch State Secretary for Tax Affairs has said.Continue Reading
United States will lose billions in tax under Pillar Two: JCT
The United States would lose over USD 120 billion in tax under the OECD’s global minimum tax, or Pillar Two, according to an analysis by Joint Committee on Taxation. Continue Reading
UK publishes draft technical guidance on Pillar Two rules
UK government has published partial draft technical guidance setting out additional information on administration, chargeability, and scope for multinational top-up tax and domestic top-up tax legislation.Continue Reading
European Commission simplifying withholding tax procedures
The European Commission has proposed new rules to make withholding tax procedures in the EU more efficient and secure for investors, financial intermediaries, and tax administrations.Continue Reading
UK modernizing transfer pricing, diverted profits tax rules
UK government is seeking stakeholders’ views on potential reforms to the UK international tax legislation on transfer pricing, permanent establishment, and Diverted Profits Tax.Continue Reading
Canada consulting on transfer pricing reform
Canada’s Department of Finance is consulting on reforming the country’s transfer pricing rules.Continue Reading
Singapore to implement Pillar 2 tax rules from 2025
Singapore will implement the Global Anti-Base Erosion (GloBE) Rules, that is, Income Inclusion Rule and Undertaxed Profits Rule, and Domestic Top-up Tax from January 1, 2025.Continue Reading
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
Sitharaman’s ‘Amrit Kaal’ Budget proposes key tax changes
Indian Finance Minister, Nirmala Sitharaman, has released the country’s latest Budget proposing a slew of tax measures.Continue Reading
International tax reform to yield significant revenue: OECD
New OECD analysis reveals that revenue from implementation of latest international tax reform measures will be higher than previously expected.Continue Reading
UK consulting on draft transfer pricing records regulations
The UK tax authority is consulting on the draft Transfer Pricing Records Regulations, 2023.Continue Reading
OECD releases key documents on two-pillar international tax reform
The OECD, today, released key documents as part of its two-pillar solution to reform international tax rules to address the tax challenges arising from globalization and digitalization.Continue Reading
EU Council agrees on minimum corporate tax rate
EU member states, on December 12, reached agreement to implement a minimum tax rate for large businesses at the EU-level.Continue Reading
UAE issues corporate tax law
On December 9, 2022, the United Arab Emirates (UAE) issued the federal law on taxation of corporations and businesses.Continue Reading
DAC6 violates lawyer-client confidentiality: CJEU
The Court of Justice of the European Union (CJEU) has held that the EU DAC6 Directive violates the right to respect for communications between a lawyer and his or her client.Continue Reading
Netherlands opposes UN international tax 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
China’s tax authority releases latest APA stats
China’s State Administration of Taxation has published the latest report on advance pricing arrangements (APAs).Continue Reading
EU lawmakers adopt tax proposal on tackling shell companies
Members of the European Parliament (MEPs) have adopted their opinion to the EU Commission’s proposed legislation aimed at clamping down on shell companies used for tax purposesContinue Reading
Netherlands to tackle “remarkable” tax avoidance arrangements
The Dutch finance ministry has launched a new project to tackle “remarkable tax arrangements.”Continue Reading
UK gets £358m in digital services tax in 2021
UK government has raised more revenue than expected in digital services tax and has increased the amount of UK tax paid by big digital companies, according to a report by the National Audit Office.Continue Reading
EU Commissioner underlines corporate tax reform plan
A global minimum corporate tax rate and the reallocation of taxing rights between jurisdictions must be implemented in due time to provide a fairer and more stable global corporate tax system, Paolo Gentiloni, European Commissioner for Economy, has said.Continue Reading
Malta gazettes transfer pricing rules
On November 18, 2022, Malta gazetted Transfer Pricing Rules, 2022.
As per the rules, in ascertaining the total income of any company:
- where any amount incurred or due, in the year preceding the year of assessment under any cross-border arrangement to which the transfer pricing rules apply, differs from the arm’s length amount, it shall be deemed that the arm’s length amount was incurred or due as opposed to the actual amount incurred or due; and
- where any amount accrued or derived, in the year preceding the year of assessment under any cross-border arrangement to which the transfer pricing rules apply, differs from the arm’s length amount, it shall be deemed that the arm’s length amount was accrued or derived instead of the actual amount accrued or derived.
OECD publishes latest corporate tax statistics
The OECD has published the latest annual Corporate Tax Statistics, covering over 160 countries and jurisdictions.Continue Reading
Luxembourg transfer pricing ruling did not favour Fiat: EU top court
The Court of Justice of the European Commission annuls the European Commission’s 2015 finding that Luxembourg granted selective tax advantages to Fiat through a transfer pricing ruling, in breach of EU state aid rules.Continue Reading
Inter IKEA Group paid less corporate income tax in 2022
The amount of corporate income taxes paid by Inter IKEA Group decreased to EUR 322 million (EUR 398 million in the 2021 financial year). However, the total tax contribution increased slightly to EUR 1,996 million (EUR 1,916 million in the 2021 financial year).Continue Reading
Profit shifting continues despite OECD, US tax reform: Research
The paper finds that global corporate profits have grown much faster than global income between 1975 and 2019. “The share of profits in global income has increased by a third over this period, from about 15 percent to close to 20 percent. This increase is due both to the rise of the share of global output originating from corporations and the rise of the capital share of corporate output,” it states.Continue Reading
EU Commission extends inquiry into Gibraltar’s corporate tax regime
The Commission has decided to extend the scope of its original investigation to specify further the measure in favour of MJN GibCo, in line with the Court’s indications, and reassess the information submitted by the UK in relation to MJN GibCo 2012 tax ruling.Continue Reading
Hong Kong bolstering cross-border tax regime
Under the new regime, taxpayers can still be exempted from tax in respect of the specified foreign-sourced passive income received in Hong Kong if they have a substantial economic presence in Hong Kong. Continue Reading
OECD tax forum releases manual on bilateral advance pricing agreements
The manual is intended as a guide to tax administrations and taxpayers for streamlining the bilateral APA process.Continue Reading
EU Council updates tax blacklist
The EU tax blacklist now consists of 12 jurisdictions: American Samoa, Anguilla, Bahamas, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, Turks and Caicos Islands, US Virgin Islands, and Vanuatu.Continue Reading
UK releases draft rules on global minimum tax
UK government, on July 20, released draft rules aimed at ensuring multinational enterprises (MNEs) operating within the UK pay a global minimum level of tax.
The draft rules are in line with the agreement on a 2 Pillar solution to reform the international tax framework made by the G20 — Organisation for Economic Co-operation and Development Inclusive Framework on Base Erosion and Profit Shifting (BEPS) last year.Continue Reading
EU Council adopts position on public country by country reporting of tax info
The reporting will take place within 12 months of the date of the balance sheet for the financial year in question. The directive sets out the conditions under which a company may defer the disclosure of certain information for a maximum of five years. Continue Reading
Anguilla, Dominica, and Seychelles removed from EU tax blacklist
Anguilla, Dominica, and Seychelles are now included in the state of play document (Annex II), which covers jurisdictions that do not yet comply with all international tax standards but that have committed to implementing tax good governance principles.Continue Reading
Global minimum tax solution to declining corporate tax rates
The data underlines the importance of the two-pillar plan being advanced by over 130 members of the OECD/G20 Inclusive Framework on BEPS to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate.Continue Reading
Ireland says no to global minimum corporate tax proposal
The consultation will run until September 10.Continue Reading
Australia designing tax policy for patent box
Comments must be received by August 16, 2021.Continue Reading
130 tax jurisdictions agree on digital economy taxation
The two-pillar package aims to ensure that large multinational enterprises (MNEs) pay tax where they operate and earn profits, while adding much-needed certainty and stability to the international tax system.Continue Reading
European Commission hails G20 agreement on digital tax
The tax reform package will include a reallocation of taxing rights – where companies pay tax wherever they conduct business – and a global minimum effective tax rate of at least 15 percent to tackle aggressive tax planning and stop the corporate tax “race to the bottom.” Continue Reading
Philippines will no longer be a harmful tax regime
The OECD’s Forum on Harmful Tax Practices (FHTP) has granted the Philippines’ appeal to assess its ROHQ regime as “potentially harmful but not actually harmful” until December 3, 2021, and then have the country’s ROHQ regime status declared as “abolished” by January 1, 2022.Continue Reading
Global minimum corporate tax protects national sovereignty: Janet Yellen
Yellen has said that the global minimum corporate tax pairs well with our domestic corporate income tax proposals and has the special virtue of helping level the playing field for US business.Continue Reading
International tax reform takes center stage in G7 meeting
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.Continue Reading
Coca Cola asks US Tax Court to reconsider transfer pricing dispute
The tax ruling was given on November 18, 2020. According to Coca-Cola, the US Tax Court’s ruling raises fundamental questions of tax, administrative, and constitutional law warranting further consideration by a full Tax Court.
The facts of the tax dispute are as follows. Upon examination of the company’s 2007-2009 returns, IRS determined that the company’s methodology did not reflect arm’s length principle because it overcompensated the supply points and undercompensated the company for the use of its intellectual property.
The US tax authority reallocated income between the company and the supply points employing a comparable profits method that used the company’s unrelated bottlers as comparable parties. These adjustments increased the company‘s aggregate taxable income for 2007-2009 by more than USD 9 billion.
In its decision, the Tax Court said that the IRS did not abuse its discretion by reallocating income to the company by employing a comparable profits method that used the supply points as the tested parties and the bottlers as the uncontrolled comparables. The US Tax Court further held that the tax authority did not err by re-computing the company’s losses after the comparable profits method changed the income allocable to the company’s Mexican supply point, a branch of the company.
In a Motion for Reconsideration of findings or opinion filed on June 2, the company said that “the IRS is attempting to impose billions of dollars in additional taxes on Coca-Cola in this case under a different tax calculation method than that on which Coca-Cola justifiably relied and which the IRS audited and approved for over a decade before retroactively requiring Coca-Cola to use a new and different method for tax years long past. The IRS’s attempt is arbitrary, capricious, and unconstitutional.”
The company added that the US Tax Court has the opportunity to correct these fundamental errors now, and with the utmost respect, Coca-Cola asks the Court to reexamine its opinion in this nationally important, precedential tax case.
The US Tax Court enjoys substantial discretion to reconsider findings of fact and conclusions of law under Tax Court Rule 161, the company said.
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
US tax committee investigating AbbVie’s tax practices
The letter states that AbbVie appears to have shifted profits offshore while reporting a domestic loss in the United States to avoid paying US corporate income tax. The Committee has asked the company to provide answers to specific tax questions no later than June 16, 2021.Continue Reading
Stakeholders engage on changes to OECD Model Tax Convention
The OECD has received comments from 22 stakeholders including the Big 4, Mexican Institute of Public Accountants, International Chamber of Commerce, European Business Initiative on Taxation, Business at OECD (BIAC), and Vienna University of Economics and Business, among others.Continue Reading
US suspends digital services tax retaliatory tariffs
On June 2, 2020, USTR initiated investigations into digital services tax adopted or under consideration in ten jurisdictions: Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the UK.Continue Reading
EU governments agree on MNE tax reporting
The reporting will take place within 12 months from the date of the balance sheet of the financial year in question. The directive sets out the conditions under which a company may obtain the deferral of the disclosure of certain elements for a maximum of five years.Continue Reading
New IMF paper on taxing multinationals in Europe
The paper analyzes corporate tax spillovers in Europe with a focus on the channels and magnitudes of both profit shifting and corporate income tax competition.Continue Reading
Joe Biden’s Budget includes key international tax measures
The Budget proposes to increase the income tax rate for C corporations from the existing rate of 21 percent to 28 percent. The proposal would be effective for taxable years beginning after December 31, 2021. Continue Reading
US Senator raises questions about Treasury’s international tax strategy
The letter states that “there is bipartisan consensus for ensuring that every country plays by the same rules, including China – as President Joe Biden recently said. No OECD agreement should provide carve-outs or exceptions for our biggest foreign competitors, including China.”Continue Reading
Global minimum corporate tax rate should be 15 percent: US Treasury
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
Parties to BEPS MLI approve key guiding principles
The Conference has agreed that as with any international agreement, the MLI shall be interpreted in good faith in accordance with the ordinary meaning to be given to the terms of the treaty in their context and in the light of its object and purpose.Continue Reading
New UN transfer pricing manual released
The Manual is focused on transfer pricing in a global environment, while it provides guidance on design principles and policy considerations. It also addresses the practical implementation of a transfer pricing regime in developing countries and shares examples of country practices from developing countries, such as Brazil, China, India, Kenya, Mexico, and South Africa.Continue Reading
Paschal Donohoe discusses international tax reform
Donohoe said that he desired “an outcome that is a fair and balanced compromise by and for all the 139 countries in the OECD Inclusive Framework.”
Ireland’s commitment remains resolute towards reaching an agreement on digital economy taxation, Ireland’s Minister for Finance, Paschal Donohoe, has said.Continue Reading
Ireland consulting on tax treaty policy
The consultation period will run until May 7, 2021.
Ireland’s Finance Minister on April 7 launched a public consultation on Ireland’s future tax treaty policy, particularly in the context of potential outcomes of international tax discussions at the OECD.Continue Reading
Fabrizia Lapecorella to chair OECD’s Committee on Fiscal Affairs from 2022
The OECD’s Committee on Fiscal Affairs has designated Fabrizia Lapecorella as the next Chair of the Committee beginning January 2022.
Lapecorella has served as Italy’s Director General of Finance since June 2008. As Director General of Finance, she is responsible for tax policy, domestic European and international, the governance of the Tax Agencies, the coordination of the IT infrastructure serving the whole Tax Administration, and the administrative services for the Tax Judicial system.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
OECD releases peer review reports on tax treaty shopping and abuse
The data compiled for this peer review demonstrate that the BEPS Multilateral Instrument has been the tool used by the vast majority of jurisdictions that have begun implementing the Action 6 minimum standard, and that the MLI has started to impact tax treaties of jurisdictions that have ratified it.Continue Reading
OECD releases MAP arbitration profiles of 30 tax jurisdictions
The Arbitration Profiles have been developed to provide taxpayers with additional information on the application of Part VI of the MLI for each jurisdiction choosing to apply that Part. The Arbitration Profiles also allow those jurisdictions to make publicly available clarifications on their position on the MLI Arbitration.
Continue Reading
US, Europe discuss digital economy taxation
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.Continue Reading
Digital services taxes of Austria, Spain and UK discriminatory: United States
In a release issued on January 14, the USTR said that the each one of these digital services taxes discriminates against US companies, is inconsistent with prevailing principles of international taxation, and burden or restricts US commerce.Continue Reading
New Zealand clarifies tax treatment of trusts under tax treaty with Australia
Comments on the Issues Paper on the tax treatment of trusts under the New Zealand-Australia tax treaty must be received by March 1, 2021.Continue Reading
US suspends retaliatory tariffs on French digital services tax
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.Continue Reading
Indian, Italian and Turkish digital service tax discriminatory: US Trade Representative
US Trade Representative has published findings on digital service tax in India, Italy, and Turkey calling it discriminatory and burdensome.Continue Reading
Malaysia gazettes transfer pricing measures
The transfer pricing measures gazetted by Malaysian government on December 31 provide a five percent surcharge in case of transfer pricing adjustments.Continue Reading
Malta publishes detailed DAC6 guidance
Maltese tax authority issues key guidance on DAC6 reportable cross-border arrangements. The guidance explains key concepts with the help of illustrations.Continue Reading
Ireland updates DAC6 guidance
The Tax and Duty Manual Manual on DAC6 has been updated in a number of respects. The updates are set out in Appendix V. Continue Reading
OECD issues guidance on transfer pricing implications of COVID-19 pandemic
The guidance on transfer pricing implications of the COVID-19 pandemic represents the consensus view of the 137 members of the OECD Inclusive Framework on BEPS.Continue Reading
OECD hails transparency on tax rulings
81 jurisdictions are now fully in line with the BEPS Action 5 minimum standard.Continue Reading
Australia to focus on tax avoidance schemes
The Australian Taxation Office said that the multinational anti-avoidance law has been successfully implemented, with the restructures resulting in more than AUD 8 billion additional taxable sales being booked in Australia.Continue Reading
Singapore tax authority clarifies deductibility of digital services taxes
The Inland Revenue Authority of Singapore stated that some jurisdictions have implemented unilateral measures to address the tax challenges of digitalization adding that “companies may have incurred additional taxes overseas due to such measures.”Continue Reading
South Africa tax authority building APA legislative framework
Comments must be received by December 18.Continue Reading
MAP cases still taking a long time to be resolved: OECD
Around 85 percent of the MAPs concluded for transfer pricing cases in 2019 fully resolved the issue, which reflects an improvement in the collaborative approach taken by competent authorities.Continue Reading
OECD releases blueprint on digital tax reform
Comments must be received by December 14.Continue Reading
Brussels to appeal Apple State aid tax case in Ireland
In July 2020, the General Court annulled the Commission’s 2016 decision concluding that Ireland granted illegal State aid to Apple through selective tax breaks.Continue Reading
Over 90 countries have law on country-by-country reporting: OECD
More than 2,500 bilateral relationships for CbC exchanges are now in place.Continue Reading
New OECD data provides insight into MNE tax activity
The data, released on July 8, is a major output based on the country-by-country reporting requirements for MNEs under the BEPS project. Continue Reading
Cameco wins Canadian transfer pricing tax dispute
That decision was unequivocally in Cameco’s favour in its dispute of reassessments issued by CRA for the 2003, 2005, and 2006 tax years.Continue Reading
Netherlands publishes much-awaited DAC6 guidance
The guidance provides detailed explanations on cross-border arrangement, definitions of intermediaries and relevant taxpayers, and the main benefit test, among others.Continue Reading
Irish tax authority extends DAC6 timelines by six months
The 30-day time period will commence on January 1, 2021. Continue Reading
UK defers DAC6 deadlines by six months
The deferral is aimed at providing taxpayers and intermediaries dealing with the impacts of the Covid-19 pandemic with additional time to ensure that they can comply with their obligations.Continue Reading
Sweden issues detailed tax guidance on DAC6
The guidance covers topics such as the purpose of reporting, the kinds of arrangements that must be reported, who should report the information, the list of information that must be submitted, and the reporting timelines.Continue Reading
No COVID support to companies that engage in tax avoidance, says Dutch government
Companies engaged in undesirable tax planning can apply for individual support if they satisfy two tax-related conditions concerning business location and transactions.Continue Reading
Unilateral action on digital economy taxation would heighten trade tensions: OECD
Gurría was responding to recent statements and exchanges regarding the ongoing negotiations to address the tax challenges of the digitalisation of the economy.Continue Reading
Netherlands mulling withholding tax on dividends paid to low tax jurisdictions
The measure will apply to financial flows to countries with a corporate tax rate of under nine percent and to countries on the EU blacklist, even if the Netherlands has a tax treaty with them.Continue Reading
Dutch tax authority publishes DAC6 guidance
The DAC6 reporting requirement will come into effect on July 1, 2020.Continue Reading
US Trade Representative to investigate digital services tax rules in EU, nine others
These ten trading partners are: Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the United Kingdom.Continue Reading
Philippines introduces bill to tax digital economy
The Bill seeks to give effect to five key changes to the way the digital economy is currently taxed, to better capture value created into the tax system.Continue Reading
EU Commission urges Ireland, Netherlands, four others to tackle aggressive tax planning
The six member states are: Cyprus, Hungary, Ireland, Luxembourg, Malta, and the Netherlands.Continue Reading
Spain’s Council of Ministers approve draft Law on DAC6
The government intends to exempt only those entities that provide legal advice.Continue Reading
European Commission defers DAC6 reporting for three months
The Commission clarified that the beginning of application of DAC6 will remain July 1, 2020, and the reportable arrangements made during the postponement period will have to be reported once the deferral has terminated. Continue Reading
Financial associations call upon EU Commission to defer DAC6 reporting
OECD issues international tax guidance in the wake of COVID-19
The Guidance notes that it is unlikely that the COVID-19 situation will create any changes to an entity’s residence status under a tax treaty.Continue Reading
UK 2020 Budget retains 19% corporate tax rate
The Government is introducing from April 1, 2020, a new two percent digital services tax on the revenues earned by certain digital businesses.Continue Reading
Norway consulting on new withholding tax on interest, royalties
Comments must be received by May 27.Continue Reading
South Africa consulting on rule to limit interest expense deduction
The Budget proposes to restrict net interest expense deductions to 30% of earnings for assessment years starting January 1, 2021.
US Congresswoman introduces public country by country reporting Bill
The report would include CbC financial filings for the information, including profits, taxes, employees, and tangible assets – that these corporations already provide to the IRS on an annual basis.Continue Reading
US government issues corrections to BEAT regulations
The corrections are effective on February 19, 2020, and apply from December 6, 2019.Continue Reading
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
New digital economy tax rules to raise USD 100 billion: OECD
The OECD analysis shows that Pillar Two could raise a significant amount of additional tax revenues.Continue Reading
OECD transfer pricing guidance on financial transactions published
The report contains guidance on how the accurate delineation analysis applies to the capital structure of an MNE within an MNE group. Continue Reading
OECD seeking input on BEPS Action 13 minimum standard
Comments must be received by March 6, 2020.Continue Reading
137 countries commit to designing rules on digital economy taxation by 2020-end
The “safe harbour” issue is included in the list of remaining work, but a final decision on this issue will be deferred until the architecture of Pillar One has been agreed upon.Continue Reading
Diverted profits tax yields UK over GBP 5 billion in extra tax
Between 2019-2020, HMRC secured GBP 480 million through DPT investigations.Continue Reading
Colombia underlines transfer pricing documentation deadlines
The deadline for filing country-by-country reports and master files is December 10-23, 2020.Continue Reading
Dominican Republic revises transfer pricing reporting threshold for 2020
The revised transfer pricing reporting threshold for 2020 is DOP11,552,402.Continue Reading
185+ organizations respond to OECD’s global anti-base erosion proposal
The OECD will hold a public consultation meeting on December 9. Continue Reading
US responds to French digital tax with USD 2.4 billion tariffs; France calls it ‘unacceptable’
French Finance Minister, Bruno Le Maire, termed the US’ proposed action as unacceptable.Continue Reading
US report on French digital services tax due next week
Earlier in July 2019, the US Trade Representative opened an investigation into whether the French DST is discriminatory in nature and harms US’ interests.
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OECD official responds to tax Professor’s views on inclusive international tax policy making
Irish corporation tax revenue touches Euros 10.4 billion
The paper highlights the marked rise in corporation tax receipts and corporate profitability since 2014.Continue Reading
Amazon underlines guiding principles on digital economy taxation
Any proposed tax must be levied on profits and not revenue, Amazon’s Vice President (Global Tax), Kurt Lamp, said.Continue Reading
OECD consulting on global anti-base erosion proposal
Comments must be received by December 2.Continue Reading
OECD consulting on digital tax proposal
Comments must be received by November 12, 2019. Continue Reading
EU Commission investigating 39 Belgian MNE tax rulings
The rulings practically resulted in over 50 percent and in some cases up to 90 percent of those companies’ accounting profit being tax exempt.Continue Reading
Transfer pricing MAP cases on the rise: OECD
According to the statistics, transfer pricing cases continue to take more time with average time being approximately 33 months (30 months in 2017).Continue Reading
OECD preparing for ‘big bang’ reform to address digital economy taxation
Gurría also described the delivery of the OECD’s BEPS package in 2015 as one of the two “big bang” developments that transformed the global tax landscape in recent years.Continue Reading
Don’t focus only on corporation tax: Amazon
Amazon is a major UK employer and currently employs over 27,500 UK people. The company said that this number would increase to over 29,500 this year.
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Glencore wins $92m transfer pricing dispute with ATO
The tax authority is considering whether to appeal the decision.Continue Reading
OECD peer review report notes progress in CbC reporting implementation
The review reveals that countries have largely adopted their domestic CbC reporting rules in line with the BEPS Action 13 minimum standard.Continue Reading
Ireland updating transfer pricing regime
The proposals would be included in Finance Bill, 2019 and, if enacted, would apply for chargeable periods commencing January 1, 2020.Continue Reading
Countries agree on proposals to fix digital economy taxation
While members of the Inclusive Framework on BEPS did not yet agree on the conclusions, they committed to work together to deliver a final report in 2020, with an update in 2019.Continue Reading
Austria mulling 5% digital tax on large businesses
Austria proposes to impose a five percent digital tax to close tax loopholes and ensure that large digital corporations are called to account.Continue Reading
OECD seeking input on digital economy taxation
Guernsey ratifies BEPS Instrument to tackle MNE tax avoidance
Ireland deposits BEPS MLI to tackle tax avoidance
For Ireland, the BEPS MLI will enter into force in May 2019.Continue Reading
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
New EU corporate tax avoidance rules enter into force
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
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
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.
Continue ReadingCountries 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 (