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TP News | TP News

By Błażej Kuźniacki (Attorney-at-Law, Deputy Director for Strategic Tax Advice & Dispute Resolution,PwC Poland) & Katarzyna Kotowska (Senior Associate, Transfer Pricing, PwC Poland) & Piotr Niewiadomski (Tax Advisor, Director in Transfer Pricing, PwC Poland)

The definition of controlled transaction in the light of Polish Corporate Income Tax Act (CIT Act) and explanatory memorandum

According to Article 11a point 6 of the CIT Act, a controlled transaction refers to economic activity identified on the basis of actual behavior of the parties to the transaction, including allocation of income to the foreign permanent establishment (PE), where the conditions are imposed/made as a result of existing relations.Continue Reading

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

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

By Aditi Sharma (Partner, Khaitan & Co, India) & Krutika Chitre (Principal Associate, Khaitan & Co, India)

The Delhi High Court in its recently pronounced decision in the case of Concentrix Services Netherlands BV WP (C) 9051/2020 and Optum Global Solutions International BV WP (C) 882/2021 invoked the ‘Most Favoured Nation’ (MFN) clause under the India-Netherlands double taxation avoidance agreement (Tax Treaty) and applied a reduced 5% withholding rate on dividend income paid by Indian companies to Dutch shareholders.

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Interpretation Note 115 relates to withholding tax on interest and Interpretation Note 116 relates to withholding tax on royalties.Continue Reading

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

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

The consultation period will run until May 7, 2021.

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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

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

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

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

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

Vice President Kamala Harris administered the oath of office to Janet Yellen on January 26, 2021.Continue Reading

The update revisits the guidance issued by the OECD Secretariat on the impact of the COVID-19 pandemic on tax treaties in April last year.Continue Reading

According to the update, Ireland will seek to implement interest limitation rules in accordance with the Anti-Tax Avoidance Directive (ATAD) standard; legislate for new international tax transparency rules for digital platforms; legislate for reverse hybrids aspect of ATAD anti-hybrid rules; adopt the authorized OECD approach for transfer pricing of branches; and consider actions that may be needed in respect of outbound payments from Ireland and our wider withholding tax regime.Continue Reading

By Simon Webber (Managing Director, Duff & Phelps LLC, New York) & Ryan Lange (Director, Duff & Phelps LLC, New York)

On October 12, 2020 the OECD/G20 Inclusive Framework (IF) released the Report on Pillar One Blueprint. This is a working document that presents the IF’s current thinking on the scope and application of changes to the international tax system to address the Tax Challenges Arising from Digitalization.  Specifically, the OECD is seeking broader consensus and approval for its proposals before moving forward further into a more detailed design.Continue Reading

The toolkit aims to help countries implement effective transfer pricing documentation requirements so that they can protect their tax bases, reduce profit shifting, and raise much-needed revenues for the recovery phase.Continue Reading

For Estonia, the BEPS MLI will enter into force on May 1, 2021. Continue Reading

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

Access to submit DAC6 reports shall be available in the coming days, the tax authority said.Continue Reading

The meeting will be held virtually and will be open to the public.

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In particular, the Presidency will address the challenges of European taxation, including the model for taxation of the digital economy, under the principles of fairness and tax efficiency.Continue Reading

The Blueprints reflect the convergent views of the Inclusive Framework on many of the key policy features, principles and parameters of both Pillars, and identify remaining technical and administrative issues as well as policy issues where divergent views among Inclusive Framework members remain to be bridged.Continue Reading

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 Trade Representative has published findings on digital service tax in India, Italy, and Turkey calling it discriminatory and burdensome.Continue Reading

If taxpayers choose to apply the indicative margin, they will apply the indicative margin on the appropriate base reference rate selected for the related-party loan.Continue Reading

The meeting will be held on January 14-15, 2021.Continue Reading

Barbados has ratified the BEPS MLI covering 31 of its tax treaties.Continue Reading

The transfer pricing measures gazetted by Malaysian government on December 31 provide a five percent surcharge in case of transfer pricing adjustments.Continue Reading

Maltese tax authority issues key guidance on DAC6 reportable cross-border arrangements. The guidance explains key concepts with the help of illustrations.Continue Reading

The UK tax authority, HM Revenue and Customs, has announced that it will repeal the DAC6 reporting requirement in 2021 and replace it with the OECD’s mandatory disclosure rules (MDR).

The announcement was made after completion of the negotiations between the UK and the EU on a Free Trade Agreement (FTA).

In a letter sent to stakeholders on December 31, HMRC said that reporting under DAC6 will still be required for a limited time, but only for arrangements which meet hallmarks under Category D, in line with the UK’s obligations under the FTA.

Category D sets out specific hallmarks concerning automatic exchange of information and beneficial ownership.

The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2) (EU Exit) Regulations, 2020 – laid before the House of Commons on December 30 – state that “(5) For the purposes of these Regulations, the DAC is to be read as if— (h) in Annex IV, Part 1 (the Main Benefit Test) and hallmark categories A, B, C and E in Part II were omitted.”

In the coming year, the UK will consult on and implement the OECD’s MDR as soon as practicable, to replace DAC6 and transition from European to international rules, HMRC told stakeholders.

Comments on the draft Circular on DAC6 must be submitted to the Italian tax authority by January 15, 2021.Continue Reading

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

Greece has dropped Oman and Seychelles from the list of preferential tax regimes for 2019.Continue Reading

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

Germany and Pakistan have deposited their instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).Continue Reading

The public consultation meeting will be held virtually on January 14-15, 2021.Continue Reading

The information provides with a better understanding of the extent to which the HTVI approach described in Chapter VI of the Transfer Pricing Guidelines has been adopted and is applied in practice by countries around the world. Continue Reading

81 jurisdictions are now fully in line with the BEPS Action 5 minimum standard.Continue Reading

Tax firm Andersen has hired Brian Untermeyer as a Managing Director in the firm’s Dallas office.

Untermeyer will join the firm’s international tax practice while serving in a key national role within the US National Tax practice. Untermeyer comes to the firm with more than 30 years of experience in advising inbound and outbound multinational public and private companies on US domestic and international tax issues across multiple industries.Continue Reading

The MNE’s suitability for ICAP will be considered on a case-by-case basis. The MNE may propose for participating tax administrations it wishes to involve in its ICAP risk assessment, which will be subject to the participating tax administrations’ agreement.Continue Reading

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

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

Canada states that Denmark’s reservation “exceeds the scope of cases for which a reservation may be made under that provision.”Continue Reading

The Plan – released on November 17 – includes guidance projects that will be the focus of efforts during the 12-month period from July 1, 2020, through June 30, 2021.Continue Reading

Richard Minor has joined the US Council for International Business (USCIB) as its International Tax Counsel.Continue Reading

Comments must be received by December 18.Continue Reading

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

DAC6 has been implemented into Maltese legislation by virtue of legal notice L.N. 342 of 2019.Continue Reading

Comments must be received by December 14.Continue Reading

The exact meeting times during this band of dates and the modalities of the meetings will be advised shortly.Continue Reading

The Suggested Approach is aimed at helping African countries that are considering implementing digital service tax to tax transactions of highly digitalized businesses.Continue Reading

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

For Jordan, the BEPS MLI will enter into force on January 1, 2021.Continue Reading

The BEPS MLI will enter into force for both countries on January 1, 2021.Continue Reading

More than 2,500 bilateral relationships for CbC exchanges are now in place.Continue Reading

The new tax treaty implements the minimum standards in accordance with the OECD’s project on base erosion and profit shifting. Continue Reading

By Dr. Björn Heidecke (Director, Deloitte Germany, Hamburg) & Tatchamon Nanavaratorn (Senior Consultant, Deloitte Germany, Hamburg)

As part of the obligation to implement the European-wide mechanism to counter base erosion and profit shifting, the German Federal Ministry of Finance circulated a draft law on 10 December 2019 (hereafter referred to as “draft law”). Besides conforming to the requirement as directed by the EU Anti-Tax Avoidance Directive, the draft law brings about the modification to the current transfer pricing legislation of both the Foreign Tax Act (Außensteuergesetz) and the Fiscal Code (Abgabenordnung), and it introduces topics not previously codified into the legislation in accordance with the BEPS concepts introduced by the OECD. The draft law takes a strict stance on businesses’ actual conducts rather than their contractual arrangements.Continue Reading

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

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

By Varapa Aurat (Consultant, Tilleke & Gibbins, Thailand) & Natthanit Mallikamal (Consultant, Tilleke & Gibbins, Thailand)

The rise of global digital economies has introduced uncertainties and exposed many loopholes in our existing tax system, with the most significant issues being the difficulties in collecting tax from those conducting digital activities without a physical presence in a jurisdiction. Thailand has long considered reforming its traditional tax system to better cover the digital economy and digital transactions, believing that foreign companies engaged in the same transactions in Thailand as local companies should also pay tax to the country. This includes value added tax (VAT) on the provision of digital services.Continue Reading

The guidance provides detailed explanations on cross-border arrangement, definitions of intermediaries and relevant taxpayers, and the main benefit test, among others.Continue Reading

The 30-day time period will commence on January 1, 2021. Continue Reading

By Husam Shareef (Partner, CTL Strategies, Maldives)

On June 10, 2020, the Maldives tax administration, Maldives Inland Revenue Authority (MIRA), issued the country’s first transfer pricing regulation. The Regulation is made pursuant to the new Income Tax Act, which came into effect from January 1, 2020. The Regulation sets out the rules to be followed by enterprises that are required to maintain transfer pricing documentation and stipulates the criteria which exempt enterprises from maintaining such documentation. The Maldives has had a corporate tax regime since July 18, 2011, however, this is the first time that taxpayers are required to follow a specific transfer pricing documentation requirement.Continue Reading

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

By Maurício Barros (Partner at Gaia Silva Gaede Advogados in São Paulo, former Taxpayer-Appointed Judge at the São Paulo Taxes and Fees Court – TIT/SP (2014-2019) and a former Visiting Professor at the Getulio Vargas Foundation and at the Mackenzie Presbiteryan University) & Luiz Guilherme de Medeiros Ferreira (Tax lawyer, São Paulo and Member of the Tax Litigation Commission at the Brazilian Bar Association)

Amid the covid-19 pandemic and the imminent financial crisis of companies, Draft Bill (DB) 2358/2020, drafted by Deputy João Maia, is making its way through the Brazilian Congress. If it becomes law, it will institute a digital services tax (DST) in Brazil, like similar taxes levied in other countries.Continue Reading

By Nishit Parikh (Partner, Sudit K Parekh & Co LLP, India)

India-Mauritius Tax Treaty has had its fair share of controversy in India. This saga continues even today, as recently Authority for Advance Ruling (‘AAR’) in India rejected a Foreign Private Equity player’s claim for Tax Treaty benefit considering the entire arrangement to be for tax avoidance.Continue Reading

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

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

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

Leading Swiss law firm Bär & Karrer has hired Raoul Stocker as a tax partner.

Raoul has 10 years of experience as a partner in tax law and is an honorary professor of tax law at the University of St. Gallen and director of the Institute of Finance and Fiscal Law.

Daniel Hochstrasser, senior partner, commented: “He will support our tax team in corporate tax law, dispute resolution in national and international tax law, as well as transfer pricing. His legal expertise and know-how will help us continue to grow our offering for our clients.”

By Catherine O’ Meara (Partner, Matheson, Dublin) 

The ability to claim relief from double taxation for transfer pricing adjustments is increasingly important as taxpayers face audits worldwide.  The Irish Revenue Commissioners (“Revenue”) have recently issued new guidelines for taxpayers seeking correlative adjustments (“CA Guidance”) in Ireland for transfer pricing adjustments by tax treaty partner jurisdictions. Continue Reading

Comments must be received by July 22.Continue Reading

By Luís Eduardo Schoueri (Full Professor of Tax Law at University of São Paulo & Senior partner at Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados) & Mateus Calicchio Barbosa (PhD Candidate and M.Sc. at University of São Paulo & Tax partner at Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)

It is said that in every crisis lies an opportunity. If the quote means that possibilities may emerge, in the tax realm taxpayers also have a new momentum to the danger component of the notion. In Brazil, outdated – not to say dangerous – tax alternatives have been put on the table to meet the recent budgetary needs. Certain wealth and capital taxes on both companies and individuals, despite previous and frustrated propositions since mid-90s, have been discussed while the government seeks a way out of an unprecedented public debt in the years to come.Continue Reading

By Kelechi Ugbeva (Managing Partner, Blackwood & Stone, Nigeria)

Existing global tax rules such as, the arm’s length principle and principle of physical presence may not be robust enough to accommodate the peculiarity of digital activities and digital taxation. To this end, the OECD has come up with a few proposals on how digital activities may be taxed. Continue Reading

The guidance states that the OECD’s Multilateral Instrument on BEPS adopted in Finland on February 13, 2019, must be taken into account when applying tax treaties.Continue Reading

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

The DAC6 reporting requirement was originally intended to take effect from July 1, 2020, postponement has been agreed in view of COVID-19 pandemic.Continue Reading

The DAC6 reporting requirement will come into effect on July 1, 2020.Continue Reading

The amendments generally apply from July 1, 2019.

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These ten trading partners are: Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the United Kingdom.Continue Reading

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

By Lokesh Shah (Partner, L&L Partners, New Delhi) & Devashish Poddar (Advocate, L&L Partners, New Delhi)

Technology, considered as a factor of production, has virtually been adopted in all sectors of the economy in order to enhance productivity, enlarge market reach, and reduce operational costs.  The adoption of technology is demonstrated by the spread of broadband connectivity in businesses, which in almost all countries of the Organisation for Economic Co-operation and Development (“OECD”) is universal for large enterprises and reaches 90% or more even in smaller businesses.Continue Reading

The six member states are: Cyprus, Hungary, Ireland, Luxembourg, Malta, and the Netherlands.Continue Reading

By Ramon Tomazela Santos (Partner, Mariz de Oliveira e Siqueira Campos Advogados)

The taxation of large technology companies has been at the center of the global debate in recent years, as their disruptive business models allows the exploitation of the market of a country without a physical presence. The underlying assumption surrounding the debate is that the application of current tax rules to companies operating in the digital economy has led to a misalignment between the place where profits are taxed and the place where value is created, due to the growing relevance of interaction and engagement with a user base for digital business.Continue Reading

The government intends to exempt only those entities that provide legal advice.Continue Reading

By Shilpa Goel (Tax Lawyer, India)

I am currently working on a case that involves questions of huge significance when it comes to related-party transactions and customs valuation. It is always good to begin with a caveat and I have two. The first is that the import in question pertains to the years 2002-2006, when the Indian custom valuation rules were somewhat different (from what they are now). The second is that I will not comment on the exact merits of the case but provide a broad overview of the legal and practical side of things.Continue Reading

By Kardelen Lule (ADMD / MAVIOGLU & ALKAN, Turkey) & Zeynep Ozbaran (ADMD / MAVIOGLU & ALKAN, Turkey)Continue Reading

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

The suspension of DAC 6 reporting obligation applies both to domestic and cross-border tax arrangements.Continue Reading

By Ritu Shaktawat (Partner, Khaitan & Co, India) Raghav Kumar Bajaj (Principal Associate, Khaitan & Co, India)

India’s Union Budget for the fiscal 2020-21 was announced in February 2020 and the tax proposals, after undergoing some important changes, were approved by the Indian Parliament and received Presidential assent on March 27, 2020. With this, the annual exercise of amending India’s tax law was completed, and the tax changes are effective from April 1, 2020.

On the tax front, some significant amendments have been made – such as widening the scope of digital tax, abolition of dividend distribution tax, more stringent tax residency rules for non-resident Indians etc.

We have analyzed here the key international tax changes impacting non-residents (MNEs and others having Indian business or nexus).Continue Reading

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

By Stefanie Perrella (Managing Director, Duff & Phelps’, New York) and Zachary Held (Director, Duff & Phelps’, New York)

On February 11, 2020, the OECD released its Final Report, Transfer Pricing Guidance on Financial Transactions, (Final Guidance), which was simultaneously incorporated into the OECD Transfer Pricing Guidelines. With respect to inter-company loans, the new Chapter X of the Transfer Pricing Guidelines is not limited to considerations for interest rate pricing, but also includes a framework for assessing the instrument’s accurate delineation as debt. Going forward, taxpayers with lenders or borrowers in OECD countries should consider this new guidance and augment their documentation accordingly. Below are some of the items that these taxpayers should consider to offer a proactive defense of potentially scrutinized areas.Continue Reading

By Luis Schoueri (University of Sao Paulo; Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados) 

Introduction

There is no divine truth about what the Arm’s Length Standard (ALS) actually means. Its content can only be determined by a decision, which can be reached by a court or by means of political consensus. There is no international tax court with jurisdiction to promote harmonization among countries on the content of the ALS and all efforts in this direction are made by means of negotiation. Such decisions affect not only the extent to which double (non-)taxation will be avoided, but also concern the country to which income is allocated, which may render the issue controversial where countries present distinct patterns of capital in- and outflow(1).Continue Reading

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

By Géry Bombeke (Partner, Baker McKenzie, Brussels)

On February 25, 2020, the Belgian Tax Administration published a new transfer pricing Circular (Circular 2020/C/35) (TP Circular) summarizing the post-base erosion and profit shifting (BEPS), OECD Transfer Pricing Guidelines and reflecting the tax authority’s views thereon.Continue Reading

Global law firm White & Case LLP has hired Will Smith as a partner in the firm’s London office.
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Emily Clark has joined corporate law firm Travers Smith LLP as head of tax.
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Comments must be received by May 27.Continue Reading

The new treaty will be effective from January 1, 2021.  Continue Reading

Julia McCullagh has joined BDO LLP’s London office as Partner, International Corporate Tax.Continue Reading

The Budget proposes to restrict net interest expense deductions to 30% of earnings for assessment years starting January 1, 2021.

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The reports highlight how well these jurisdictions are implementing BEPS Action 14 minimum standard on making tax treaty dispute resolution more timely, effective, and efficient.Continue Reading

International Tax Authority informs BVI Constituent Entities, that are part of Multinational Entity Group, that it will soon be ready to receive filings for CbC reporting.Continue Reading

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

The corrections are effective on February 19, 2020, and apply from December 6, 2019.Continue Reading

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

The OECD analysis shows that Pillar Two could raise a significant amount of additional tax revenues.Continue Reading

The report contains guidance on how the accurate delineation analysis applies to the capital structure of an MNE within an MNE group. Continue Reading

Comments must be received by March 6, 2020.Continue Reading

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

Between 2019-2020, HMRC secured GBP 480 million through DPT investigations.Continue Reading

The webcast will be held on January 31, 2020, at 14:00-15:00 (CET).Continue Reading

The BEPS MLI will enter into force for these two countries on May 1, 2020.Continue Reading

The deadline for filing country-by-country reports and master files is December 10-23, 2020.Continue Reading

The BEPS MLI will enter into force for  Liechtenstein on April 1, 2020.Continue Reading

The tax treaty applies from January 1, 2020.Continue Reading

The revised transfer pricing reporting threshold for 2020 is DOP11,552,402.Continue Reading

The tax treaty will become effective after both countries have completed their respective domestic procedures.Continue Reading

The OECD will hold a public consultation meeting on December 9. Continue Reading

French Finance Minister, Bruno Le Maire, termed the US’ proposed action as unacceptable.Continue Reading

The Commission may bring the cases before the Court of Justice of the EU if Austria and Ireland do not act by February 1, 2020.Continue Reading

The tax treaty and Protocol implement the BEPS minimum standards to tackle tax planning strategies that exploit gaps and mismatches in tax rules.Continue Reading

International tax veteran Brian Abbey has joined Global Tax Management as Managing Director, International Tax.Continue Reading

Transfer pricing specialist Kevin Norton has joined Deloitte Ireland’s tax team as partner.Continue Reading

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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The tax treaty will enter into force after both countries have completed their respective internal procedures.Continue Reading

Comments must be received by December 16, 2019.Continue Reading

The paper highlights the marked rise in corporation tax receipts and corporate profitability since 2014.Continue Reading

Any proposed tax must be levied on profits and not revenue, Amazon’s Vice President (Global Tax), Kurt Lamp, said.Continue Reading

Comments must be received by December 2.Continue Reading

The protocols contain an anti-abuse clause.Continue Reading

The additional interpretative guidance will help MNE Groups in avoiding common errors made in preparing CbC reports.Continue Reading

Comments must be received by November 12, 2019. Continue Reading

For Denmark the BEPS MLI will enter into force on January 1, 2020.Continue Reading

By Ricardo Rendón (Partner, Chevez, Ruiz, Zamarripa y Cía, S.C., Mexico)

On September 8, 2019, the Executive Branch of the Mexican Government submitted to the Congress Tax Reform for 2020, which includes key tax changes to the country’s tax law primarily inspired by the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading

By Catherine O’ Meara (Partner, Matheson, Dublin)

The Irish Government recently published a Transfer Pricing Rules Feedback Statement, which confirms that changes to the country’s transfer pricing rules and their implementation are forthcoming.Continue Reading

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

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

Comments must be received by October 4, 2019.Continue Reading

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

Japan and Peru have “in principle” agreed to conclude a tax treaty.Continue Reading

The Protocol will be effective for requests for information made on or after the date of entry into force for tax years on or after January 1, 2009.Continue Reading

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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Global law firm Shearman & Sterling has roped in Jay Singer as partner to the firm’s tax practice. Jay will be based in the firm’s Washington, D.C. office.Continue Reading

The tax authority is considering whether to appeal the decision.Continue Reading

The review reveals that countries have largely adopted their domestic CbC reporting rules in line with the BEPS Action 13 minimum standard.Continue Reading

The proposals would be included in Finance Bill, 2019 and, if enacted, would apply for chargeable periods commencing January 1, 2020.Continue Reading

Mandatory binding arbitration clause is included in the tax treaty protocols to resolve tax treaty disputes.Continue Reading

A former US Treasury international tax Counsel, Brian Jenn, has joined McDermott Will & Emery as its partner.

Jenn will be based out of the firm’s Chicago office.Continue Reading

Hong Kong issues guidance to ensure compliance with the country’s transfer pricing documentation requirements.Continue Reading

The BEPS MLI will enter into force in both countries on December 1, 2019.Continue Reading

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

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Principal, Transfer Pricing Services, SKP Group)

On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill). 

This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations under BEPS Action Plans.Continue Reading

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

For Georgia the BEPS MLI will enter into force on July 1, 2019. Continue Reading

Armenia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading

Transfer pricing advisory Questro International has hired Chris Whitehouse as a transfer pricing partner for its Zurich office.

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For Ireland, the BEPS MLI will enter into force in May 2019.Continue Reading

Hong Kong Inland Revenue Department has clarified that starting from April 2019, the Department will not accept voluntary filing of a country-by-country (CbC) report for an accounting period ended on or before March 31, 2018.Continue Reading

Transfer pricing specialist Questro International has hired Manuel Koch as a Partner for the firm’s office in Stuttgart, Germany.

Koch brings significant experience of over ten years specialization in transfer pricing consulting. Koch has wide experience in international tax planning engagements for international corporates including holding and principal structures as well as Swiss finance branches and IP boxes.Continue Reading

Global advisory firm Duff & Phelps has announced that Jill Weise will succeed Michael Heimert as the Global Leader for the firm’s transfer pricing practice.

Weise has nearly 25 years of expertise in transfer pricing. She previously served as the firm’s transfer pricing practice leader for North America.
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By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)

In India, the 2016 Finance Act introduced a three-tiered transfer pricing documentation regime with a view to aligning the Indian transfer pricing documentation rules with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.

Accordingly, Indian subsidiaries of multinational groups were required to comply with new “master” and “local” files requirements and a new country-by-country reporting requirement from the 2016-17 financial year.Continue Reading

Transfer pricing expert Mark Madrian has joined Valentiam Group as a Partner in the firm’s West Coast practice.

Madrian has advised clients on complex cross-border transfer pricing and other international tax issues. He was recently recognized as a Leading Transfer Pricing Adviser by Legal Media.
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The treaty will be effective from April 1, 2019.Continue Reading

By Anas Salhieh  (Senior Tax Executive, Al Tamimi & Company, Riyadh, Saudi Arabia)

Saudi Arabia’s General Authority for Zakat and Income Tax has published for public comments draft transfer pricing bylaws as part of the Kingdom of Saudi Arabia’s commitment to the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading

Cook Islands has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading

Jeffrey Tate has joined US law firm Arent Fox’s tax practice as a Partner.

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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

The OECD has made 60 jurisdiction-specific recommendations on issues such as improving the timeliness of the exchange of information and ensuring that exchanges of information are made with respect to preferential tax regimes that apply to income from intellectual property.Continue Reading

By Elizabeth Sidi (Senior Tax Consultant, PwC, Bulgaria) 

Bulgaria is introducing new interest limitation rules and a new controlled foreign corporation regime from January 1, 2019. 

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Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.

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The legislation is intended to enter into force in July 2019. Continue Reading

By Catherine O’ Meara (Partner, Matheson, Dublin) and Brian Doohan (Senior Associate, Matheson, Dublin)

On November 27, 2018, Ireland’s Finance Minister Paschal Donohoe announced the details of a Competent Authority Agreement between Ireland and Malta (Agreement). The clear aim of the Agreement is to end what is referred to as the “Single Malt” tax structure.Continue Reading

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The Belgian tax authority has issued a draft Circular on the 2017 update to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.Continue Reading

Qatar is the 85th jurisdiction to sign the BEPS Convention, which now covers nearly 1,500 bilateral tax treaties.Continue Reading

An arbitration clause is included in the new tax treaty to resolve double taxation disputes.Continue Reading

The tax treaty provides for a low withholding tax rate of five percent for dividend payments. Interest, royalties, and fees are subject to a low withholding tax rate of ten percent.Continue Reading

The Australian tax authority has allowed “significant global entities” time until January 15, 2019, to lodge their country-by-country (CbC) reports.
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The Australian Taxation Office is reviewing international arrangements that mischaracterize intangible assets to understate Australian profits.
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India has signed a Protocol to amend its tax treaty with China.

The Protocol incorporates changes required to implement tax treaty-related minimum standards agreed under the base erosion and profit shifting (BEPS) project.
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Dealing with cases that have potential transfer pricing implications in Panama requires a high level of expertise in the realm and an extended experience in cases where the common OECD practices are not applicable (Panama is not a member of the OECD).

Panama’s transfer pricing regime constitutes a hybrid insofar as OECD Transfer Pricing Guidelines are concerned. While the OECD Transfer Pricing Guidelines cannot be applied directly, they could be relied upon for interpreting rules provided they are not in conflict with the Panamanian Tax Law. Thus, a transfer pricing study undertaken by one experienced in non-OECD tax jurisdictions – such as www.transferpricing.com.cy – is recommended.Continue Reading

The Norwegian Government has submitted to the Parliament a proposal to ratify the OECD’s Multilateral Instrument to implement tax treaty-related measures to tackle base erosion and profit shifting (BEPS).Continue Reading

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The EU Joint Transfer Pricing Forum has published a report, which aims to address the lack of guidance on bilateral and multilateral transfer pricing audits.
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DIGITALEUROPE, which represents the digital technology industry in Europe, has called upon governments to negotiate a comprehensive, global, long-term tax solution at the OECD-level to address the tax challenges of the digital economy.
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Cabo Verde is the newest member to the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
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On November 14, 2018, Ireland’s Department of Finance published for public comments a consultation document on the hybrid mismatch and interest limitation measures to be introduced as part of the implementation of the EU Anti-Tax Avoidance Directives (ATAD and ATAD2).
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China’s colossal economy and its predominant role within the global market result in the emergence of an increasing interest towards China’s transfer pricing regime. Since China is not a member of the OECD, any transfer pricing endeavor goes far beyond the classic transfer pricing practices, though.Continue Reading

By Erinda Xhaferraj (Tax Manager, PwC, Albania) and Edland Graci (Transfer Pricing Senior Associate, PwC, Spain)

The amendment in 2014 of Albania’s Income Tax Law and the release of the Transfer Pricing Instruction introduced changes that are of importance to Albanian taxpayers performing cross-border transactions. For the first time taxpayers were faced with a complex and sophisticated legislation, which required the application of arm’s length in intra-group transactions.Continue Reading

The OECD is seeking taxpayers’ input for the seventh round of base erosion and profit shifting (BEPS) Action 14 Stage 1 peer reviews of further eight jurisdictions.
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The OECD has published new guidance for the development of synthesised texts to facilitate the interpretation and application of tax agreements modified by the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI).Continue Reading

More than 60 delegates from 16 countries met recently at the regional meeting of the Inclusive Framework on base erosion and profit shifting (BEPS) in Eastern Europe and Central Asia to discuss implementation of the BEPS measures.Continue Reading

The Jersey Government has issued details of new legislation that would introduce economic substance requirements for companies resident in Jersey for tax purposes.Continue Reading

Loren Ponds has joined US law firm Miller & Chevalier as a Member in the firm’s tax department.

Previously, Ponds served as Tax Counsel to the US House of Representatives Committee on Ways and Means, where she was instrumental in the development of the international tax provisions included in the Tax Cuts and Jobs Act of 2017.Continue Reading

The UK Government is seeking stakeholders’ views on the detailed design, implementation, and administration of the proposed two percent digital services tax (DST).Continue Reading

By Ritu Shaktawat (Partner, Khaitan & Co, India) and Shabnam Shaikh (Principal Associate, Khaitan & Co, India)

In a decision delivered on October 5, India’s Income Tax Appellate Tribunal, New Delhi ruled that the Indian Income Tax Act cannot limit the claim of expenses of a permanent establishment in the absence of such limitation in the India-Mauritius tax treaty.Continue Reading

Grenada has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading

Senior tax experts met at an event in Portugal on October 23 to discuss the strategic importance of the OECD’s work on base erosion and profit shifting (BEPS) and the challenges faced by tax administrations in implementing the BEPS proposals.Continue Reading

Antigua and Barbuda, Dominica, and Saint Vincent and the Grenadines have newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).

The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading

Japan and Spain signed a new tax treaty on October 16. The tax treaty wholly amends the existing tax treaty between Japan and Spain, which entered into force in 1974.

As per the new tax treaty, a withholding tax exemption applies to investment income from interest and royalties. Withholding tax on dividends is also exempt in certain situations.Continue Reading

Japan and Croatia signed a new tax treaty on October 19.

The new tax treaty provides for a reduced withholding tax on dividends, interest, and royalties. In some case, these are exempt.Continue Reading

The Swiss Federal Council on October 17 decided to expand the list of countries with which Switzerland would exchange country-by-country (CbC) reports.

The legal basis for the exchange of CbC reports entered into force for Switzerland on December 1, 2017. Switzerland had then submitted to the OECD a list of 108 countries with which the Government will exchange CbC reports.Continue Reading

The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.

According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading

Leading audit, tax, and consulting firm RSM has appointed two new tax directors to join the firm’s Manchester office.Continue Reading

Liberia is a typical example amongst developing African countries making noticeable effort to expand their tax base to the size it should appropriately be, therefore collecting more taxes and adapting to the fast-changing local and global business environment.Continue Reading

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The Large Enterprises Division of the Belgian tax administration has announced the launch of a two-year pilot project aimed at transforming the traditional approach of ex-post tax investigations towards a system of proactive, real-time, and constructive dialogue on corporate tax affairs.

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The Australian Taxation Office has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes.Continue Reading

Dominican Republic has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading

The tax treaty between Japan and Iceland will enter into force on October 31, 2018, Japan’s Finance Ministry has announced.Continue Reading

The protocol to amend the Switzerland-Latvia tax treaty entered into force on September 3, 2018, and will take effect from January 1, 2019. Continue Reading

Senior tax officials from over 20 countries recently met at a workshop to share experiences from the first year of country-by-country (CbC) reporting and explore how information can be used most effectively in the tax risk assessment of MNE groups.Continue Reading

Aruba has now joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).

The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading

Australia, France, Japan, and the Slovak Republic have deposited their instruments of ratification of the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).

For these four countries, the BEPS Convention would enter into force from January 1, 2019. The Convention entered into force last month for New Zealand, Serbia, Sweden, and the UK.Continue Reading

By Adv. (Eco.) Eyal Bar-Zvi (Partner and Head of Transfer Pricing, Herzog Fox & Neeman)

The Israel Tax Authority, on September 5, 2018, published two safe harbor Circulars (which remained in draft mode for several months), noting the tax authority’s expected profit levels for marketing services and for low-risk distributorship activities carried out in Israel by multinational entities (MNEs), and providing guidance on non-value-added services.Continue Reading

Saudi Arabia has become the 84th tax jurisdiction to sign the base erosion and profit shifting (BEPS) Multilateral Convention.

The BEPS Convention, negotiated by over 100 countries and jurisdictions, updates the existing network of 1,400 bilateral tax treaties and reduces opportunities for tax avoidance by multinational enterprises.Continue Reading

The International Chamber of Commerce (ICC) has largely welcomed the OECD’s public discussion draft on the transfer pricing aspects of financial transactions.

The discussion draft deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.Continue Reading

The OECD has published a set of newly established bilateral for the exchange of country-by-country (CbC) reports with respect to Bermuda, Curaçao, Hong Kong (China), and Liechtenstein.Continue Reading

The US Senate has, by a 64 – 33 vote, confirmed Charles Rettig to be the new Internal Revenue Service (IRS) Commissioner.

During his more than 35 years of professional career with Hochman, Salkin, Rettig, Toscher & Perez, PC, Rettig represented numerous taxpayers before every administrative level of the IRS as well as in matters before the Tax Division of the US Department of Justice, and various other tax authorities.Continue Reading

Former OECD Head of Transfer Pricing, Jefferson P. VanderWolk, has joined international law firm Squire Patton Boggs as a partner in the Tax Strategy & Benefits Practice. VanderWolk will work from the firm’s Washington DC office.Continue Reading

The OECD has issued further interpretative guidance on the implementation of country-by-country (CbC) reporting to provide certainty to tax administrations and multinational enterprises (MNEs).Continue Reading

Israel and Lithuania have newly deposited with the OECD their instrument of ratification for the Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading

By Amaka Samuel Onyeani (Senior Manager, Transfer Pricing, Andersen Tax, Nigeria) & Abisola Agboola (Assistant Manager, Transfer Pricing, Andersen Tax, Nigeria)

Nigeria’s Federal Inland Revenue Service (FIRS) recently released the revised Income Tax (Transfer Pricing) Regulations, 2018 (the Transfer Pricing Regulations). The Transfer Pricing Regulations are one of the efforts of the FIRS in improving the administration of transfer pricing in the country, increasing revenue collection via taxes, and protecting Nigeria’s tax base.Continue Reading

The Tax Executives Institute has responded to the OECD’s public discussion draft on the transfer pricing aspects of financial transactions.

The discussion draft deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.Continue Reading

The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa, and Turkey. The OECD has also updated the information contained in Singapore’s profile.Continue Reading

By Mika Ohtonen (Head of Tax, Roschier, Finland) & Laura Puro (Senior Associate, Roschier, Finland)

Finland’s Ministry of Finance last month published a draft proposal on amending the Finnish controlled foreign corporation (CFC) statute. While the purpose of the draft is to implement the CFC provisions of the Anti-Tax Avoidance Directive (ATAD), the proposed changes are materially stricter than required by the ATAD.Continue Reading

A new OECD report reveals that countries have used recent tax reforms to lower corporate income tax.

Tax Policy Reforms 2018 highlights the continuation of a trend toward corporate income tax rate cuts, which has been largely driven by significant reforms in a number of large countries with traditionally high corporate tax rates.Continue Reading

India’s tax authority has extended the earlier deadline of August 10 to submit comments on the newly introduced “significant economic presence” test to tax profits of foreign businesses.Continue Reading

Transfer pricing advisory firm Quantera Global has announced its strategic partnership with Africa Transfer Pricing, a professional services firm specializing in transfer pricing in South Africa.Continue Reading

The South African Revenue Service (SARS) is re-establishing the Large Business Unit to ensure that the unit is responsive to the challenges currently being faced by SARS.Continue Reading

The Former Yugoslav Republic of Macedonia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading

The Swiss Federal Council on August 22 adopted the dispatch concerning a protocol of amendment to the Swiss-UK tax treaty for the attention of Parliament.Continue Reading

By Sami Tuominen (Partner, Head of Tax, Bird & Bird, Finland) &  Marianna Santamala (Associate, Bird & Bird, Finland)

The Finnish Ministry of Finance recently proposed amendments to the current Finnish legislation concerning controlled foreign corporations (CFC). On August 6, 2018, the Finance Ministry submitted a proposal for Government Bill on the amendments to the Act on taxation of members of controlled foreign companies (Act). The Act is currently going through a consultation round and the Ministry would accept input until the end of this month. The purpose of the Act is to prevent the avoidance of taxation in Finland by utilizing corporations established in states with low taxation.Continue Reading

By Ricardo Rendón (Partner, Chevez, Ruiz, Zamarripa y Cía, S.C., Mexico)

The Mexican tax authorities last month issued the Second Resolution of modifications to the 2018 Miscellaneous Tax Resolution (MTR) in which the rules regarding transfer pricing adjustments were amended and certain additional provisions were included. This article discusses the relevant modifications to the miscellaneous tax rules on transfer pricing adjustments.Continue Reading

The Swiss Federal Council on August 15 adopted the dispatch on the tax treaty with Saudi Arabia.Continue Reading

By Stefaan De Ceulaer (Director, Tax and Legal Support, PKF International)

The Belgian Parliament on June 29 adopted the Programme Act, which introduces in Belgian tax law specific transfer pricing documentation requirements, that is, in article 321/1 to 321/7 of the Income Tax Code (Programme law of July 1, 2016 gazetted on July 4, 2016), in response to Action 13 of the OECD’s base erosion and profit shifting (BEPS project.  Continue Reading

In a significant expansion drive, Grant Thornton, leading audit, tax, and advisory firm, has added offices in Aruba, Bonaire, Curaçao, and St. Maarten, boosting its already wide presence in 13 locations across the Caribbean.Continue Reading

By Marcin Jamroży (Associate Professor, Warsaw School of Economics, and Partner, Rödl & Partner, Poland)

Poland’s Finance Ministry recently published a draft tax Bill to implement key changes to the country’s transfer pricing documentation rules. The draft Bill is aimed at simplifying Poland’s transfer pricing regulations and lowering the bureaucratic and administrative burden for enterprises. The philosophy of a simple, transparent, and friendly tax system should be written into the law. At the same time, it is underlined that the draft Bill should be sealed against loopholes and incorporate the new OECD recommendations. The new regulation is proposed to be effective from January 1, 2019.Continue Reading

Taxpayers can report rounded figures in their country-by-country (CbC) reports, Singapore’s tax authority has clarified.Continue Reading

India’s Central Board of Direct Taxes (CBDT) entered into nine new unilateral advance pricing agreements (APAs) in July 2018, the tax authority has announced.Continue Reading

By Mario Ortega Calle (Partner, Garrigues, Madrid) and Laura Jiménez (Associate, Garrigues, Madrid)

Spain’s General State Budget for 2018, published by Law 6/2018 of July 3, 2018, in the Official Gazette, has amended the country’s patent box regime to bring it in further alignment with the “nexus approach” developed by the OECD under Action 5 of the base erosion and profit shifting (BEPS) project.Continue Reading

Guernsey’s Government is consulting businesses on a law that would require companies tax-resident in Guernsey to demonstrate they have sufficient substance in the island.Continue Reading

The Australian Taxation Office (ATO) has published for public comments Schedule 2 to Practical Compliance Guideline (PCG) 2017/4DC, which discusses the tax authority’s  compliance approach to tax issues relating to cross-border, related-party financing arrangements and related transactions.Continue Reading

Japan and Colombia have completed tax treaty negotiations, Colombia’s Finance Minister, Mauricio Cárdenas, announced on July 30.Continue Reading

The tax treaty between Singapore and Nigeria will enter into force on November 1, 2018, and will take effect on January 1, 2019.Continue Reading

By Ross B. Newman (CEO and Chief Economist with Altus Economics and Chairman of the Altus Transfer Pricing Network) 

The US Internal Revenue Service (IRS) on June 29 issued the Transfer Pricing Examination Process (TPEP), which replaces the 2014 Transfer Pricing Audit Roadmap (Roadmap) and provides a guide to best practices and processes involved in the three phases of a transfer pricing examination: planning, execution, and resolution.

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New Zealand’s Inland Revenue today announced that the Government has ratified the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).Continue Reading

Taiwan’s Finance Ministry is holding the 2018 International Tax Academy from July 30 to August 17 this year.

The event was launched in 1984 and is conducted every year in cooperation with the School of Law of Southern Methodist University.Continue Reading

South Africa’s tax authority on July 25 published general guidance on the mutual agreement procedure (MAP) framework incorporated in tax treaties to resolve disputes.Continue Reading

Global law firm DLA Piper has announced the appointment of Vicki Bales as a Transfer Pricing director in the firm’s international tax practice. Bales will be based in London.Continue Reading

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

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

Houthoff, one of the largest law firms in the Netherlands, has hired Franka Sturm as Counsel for the firm’s tax practice.

Sturm has over 13 years of experience as a tax specialist in international practice with a focus on M&A and oil and gas.

Before joining Houthoff, Sturm worked with the Dutch Tax and Customs Administration and with PwC as a Senior Tax Manager.

Canada’s tax authority has completed 36 advance pricing agreements (APAs) in the 2017 calendar year, according to latest statistics published on the country’s APA program.Continue Reading

The US Internal Revenue Service (IRS) has issued key guidance on best practices and processes to assist with the planning, execution, and resolution of transfer pricing examinations.Continue Reading

By Ritu Shaktawat (Associate Partner, Khaitan & Co, India) and Krutika Chitre (Associate, Khaitan & Co, India)

Ritu Shaktawat and Krutika Chitre of Khaitan & Co discuss the consultation document addressing the tax challenges of digital economy released by Indian’s Central Board of Direct Taxes on July 13, 2018.

Soon after having introduced ‘Google Tax’ in 2016, India becomes one of the first tax jurisdictions to treat ‘significant economic presence’ of a foreign enterprise as its taxable presence in India (effective from April 1, 2018 (that is, from assessment year 2019-20)).Continue Reading

Audit, tax, and consulting firm RSM has appointed Robert De La Rue, former Head of Tax of Jardine Motors Group, as a tax partner in Chelmsford.Continue Reading

The OECD is seeking taxpayers’ input for the sixth round of base erosion and profit shifting (BEPS) Action 14 Stage 1 peer reviews of eight new jurisdictions.Continue Reading

By Reuven Avi-Yonah (Irwin I. Cohn Professor of Law, University of Michigan)

On July 24, 2018, the Ninth Circuit Court of Appeals reversed the US Tax Court decision in Altera Corp. v. Commissioner, 145 T.C. 91 (July 27, 2015), which had invalidated Treas. Reg. § 1.482- 7A(d)(2).(1)Continue Reading

Ukraine has become the 83rd tax jurisdiction to sign the base erosion and profit shifting (BEPS) Multilateral Convention.Continue Reading

Senior tax officials from 20 countries in Europe and Central Asia recently met in Georgia to discuss ways to tackle tax avoidance and to implement the base erosion and profit shifting (BEPS) proposals.Continue Reading

Law firm Baker McKenzie has announced the election of 13 new tax partners.

The newly elected partners are: Michael Nixon (Singapore), Simone Bridges (Sydney), Kirill Vikulov (Moscow), David Jamieson (London), Jessica Eden (London), Rodrigo Castillo Cottin (Bogota), Paul F. DePasquale (New York), Tatyana Johnson (New York), Victor Alejandro Morales-Chavez (Mexico City), Jonathan Welbel (Chicago), Joshua Nixt (New York), Andrew C. O’Brien-Penney (Chicago), and Ivan Tsios (Chicago).Continue Reading

Artur Braga has joined São Paulo firm WZ Advogados as a Tax Partner.

Braga joined WZ Advogados after a 20-year career at Ernst and Young (EY). Braga specializes in advising clients in cross-border tax planning, tax litigation, audit reviews, mergers and acquisitions, and corporate restructurings.Continue Reading

By Diletta Fuxa (Senior Manager), Studio Associato Servizi Professionali Integrati, Member of Fieldfisher

On May 14, 2018, Italy’s Ministry of Economy and Finance issued a Decree, which lays down new transfer pricing guidelines in compliance with the provisions set forth in article 110 (7) of the Income Tax Code (Testo Unico delle Imposte sui Redditi).Continue Reading

The Platform for Collaboration on Tax – a joint initiative of the IMF, the OECD, the UN, and the World Bank Group – has published for public comments a revised version of its report on taxation of offshore indirect transfers of assets.Continue Reading

The UK Government has published a final list of its reservations and notifications under the Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading

Canada has successfully initiated its first round of exchanges of country-by-country (CbC) tax reports of multinational enterprises (MNEs), Diane Lebouthillier, Minister of National Revenue, has announced.Continue Reading

The Australian Taxation Office (ATO) on July 4 issued Tax Determination (TD) TD 2018/12, which provides guidance on the application of “direct connection test” under the Multinational Anti-Avoidance Law (MAAL).Continue Reading

By Daksha Baxi (Head of International Taxation, Cyril Amarchand Mangaldas) and Jyoti Anumolu (Associate, Cyril Amarchand Mangaldas)

India’s Income Tax Appellate Tribunal (ITAT) at New Delhi last month delivered a significant decision in the case of Nokia Networks OY (taxpayer) on the issue of whether it’s Indian subsidiary, Nokia India Private Limited (NIPL) (which was assigned installation contracts by the taxpayer or entered into independent installation contracts with customers) constituted a permanent establishment (PE) for the taxpayer.Continue Reading

India’s Central Board of Direct Taxes (CBDT) entered into three new unilateral advance pricing agreements (APAs) in the months of May and June 2018, the tax authority revealed.Continue Reading

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

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

The governments of UK and Isle of Man signed a new tax treaty on July 2.

The tax treaty is based on the latest OECD Model Tax Convention and includes provisions to reflect the OECD’s base erosion and profit shifting (BEPS) measures.Continue Reading

The OECD today called for stakeholders’ input on a discussion draft on financial transactions, which deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.
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By Josh Bamfo (Partner & Head, Transfer Pricing Services, Andersen Tax, Nigeria)

The Federal Government of Nigeria finally published the much anticipated Income Tax (Country-by-Country Reporting) Regulations, 2018 (the CbC Regulations) on June 19, 2018 (with a commencement date of January 1, 2018). This is in line with Nigeria’s signing of the OECD’s Multilateral Competent Authority Agreement on January 27, 2016, providing for automatic exchange of CbC reports.

As a sequel to my earlier publication on the potential implications of the draft CbC reporting Regulations to affected taxpayers, which was published four months ago, this article presents the key highlights of the CbC reporting Regulations and re-assesses the potential implications based on the content of the final, published version.Continue Reading

Tax and business advisory firm True Partners Consulting has promoted Matthew John McNally to the position of Managing Director in New York. He leads the firm’s partnership tax group in the northeast.Continue Reading

Tax expert Anthony (Tony) Carbone has joined leading law firm Morrison & Foerster to serve as co-chair of the firm’s Global Tax Department.Continue Reading

On June 21, 2018, the Australian Taxation Office (ATO) published for stakeholders’ comments draft Practical Compliance Guideline (PCG 2018/D4) to assist taxpayers who may be affected by the country’s hybrid mismatch rules and wish to unwind or restructure out of existing hybrid arrangements.Continue Reading

Global advisory firm Duff & Phelps has hired Ted Keen, who will serve as the European leader for the firm’s transfer pricing practice from London.Continue Reading

Introduction

The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD to counter tax base erosion is dim long over-due. Indeed, the case with transfer pricing is technically considered a neutral concept but erroneously taken as an offensive action of MNEs that permits them to transfer profits generated by intangibles to so-called tax havens. Although, the arm’s length principle enshrine in the OECD Model has been misidentified as the primary instrument to tackle such abusive behavior of MNEs.Continue Reading

The UAE has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).

The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading

Introduction

When states attain membership of the European Union (EU), the governments are in charge of enacting and implementing their local direct taxation policy. The tax framework of the member-states shall not contravene or interfere the laid down policies and directives of the EU institutions; therefore, the sovereignty of member states is extremely safeguarded. Although the EU faces difficulties to come up with results that would be generally accepted by all member states, it has taken every step to integrate all Member States’ corporate direct taxation systems since the 1950s.Continue Reading

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)

As an active participant in the OECD’s base erosion and profit shifting (BEPS) project, India has implemented nearly all the BEPS recommendations and has taken several steps to amend the country’s domestic tax laws appropriately. The Indian Finance Act, 2016 implemented BEPS Action Item 13 by introducing a three-tiered transfer pricing documentation structure and made it effective from the 2016-17 financial year.Continue Reading

The Indian tax authority has published for public comments a draft Notification, which will implement the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project.Continue Reading

Former Microsoft Tax Counsel, Mike Bernard, has joined US tax technology solutions company Vertex, Inc as the Chief Tax Officer. Bernard will succeed Peggi Rockefeller.Continue Reading

India’s Union Cabinet has approved revision of the country’s tax treaty with Qatar.

The revised tax treaty includes a limitation of benefits clause to prevent treaty shopping. It meets the base erosion and profit shifting (BEPS) minimum standards on treaty abuse (BEPS Action 6) and mutual agreement procedure (BEPS Action 14).Continue Reading

The OECD has released additional guidance on the attribution of profits to permanent establishment (PE), as part of its work on base erosion and profit shifting (BEPS) Action 7.Continue Reading

The Indian Government has approved the country’s tax treaty with Iran.

The tax treaty is in line with the ones entered into by India with other countries. The proposed treaty also meets tax treaty-related minimum standards proposed under the OECD’s base erosion and profit shifting project, in which India is participating on an equal footing.Continue Reading

On March 12, 2018, the OECD published mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain. Continue Reading

Austria’s leading tax lawyer, Franz Althuber, has left DLA Piper to start his own firm, Althuber Spornberger & Partners.Continue Reading

By Debora De Souza Correa Talutto (Group Transfer Pricing Manager, Temenos Banking Software Co.)

The Brazilian transfer pricing rules were created to address the maximum tax deductible costs or expenses when domestic taxpayers buy goods and services from foreign suppliers, and the minimum taxable revenues when local companies sell goods and services to foreign customers.Continue Reading

On March 5, 2018, the Hong Kong Government launched an online portal to enable Hong Kong entities to file their country-by-country (CbC) reports. The Portal can be accessed through: https://aeoi.ird.gov.hk/cbc.Continue Reading

Anguilla has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading

The arm’s length principle treats the members of a multinational enterprise (MNE) as operating in separate entities, rather than as inseparable parts of a single, unified business. Therefore, it is required that MNEs follow the same pricing policy for intra-group and uncontrolled transactions, under comparable circumstances. Otherwise, the controlled companies shall take the necessary measures and adjust their profits by reference to the conditions, which would have obtained between independent enterprises.Continue Reading

The UK Government has published an Order, which would update the definition of “transfer pricing guidelines” in the UK legislation.Continue Reading

David Lewis has joined Duff & Phelps’ as a managing director in the firm’s transfer pricing practice. Lewis will be located in Melbourne, Australia.Continue Reading

The Australian Taxation Office (ATO) will release this year detailed advice and guidance on the country’s thin capitalization regime contained in Division 820 of the Income Tax Assessment Act, 1997.Continue Reading

An amending Protocol to the UK-Mauritius tax treaty was signed on February 28, 2018.Continue Reading

Singapore and Tunisia have signed a tax treaty, which provides for low withholding tax rates and a detailed exchange of information provision.Continue Reading

India’s Central Board of Direct Taxes (CBDT) entered into a further seven unilateral advance pricing agreements (APAs) in February 2018, taking the total number of APAs signed to 203.Continue Reading

By Marco Greggi (Professor, International Tax Law, University of Ferrara)

The Italian Finance Ministry, on February 21, 2018, published for stakeholders’ comments two draft transfer pricing regulations. The first Regulation is a proposed decree that deals with substantive aspects of transfer pricing regulations (analyzed in this article), while the second Regulation concerns corresponding adjustments (procedural aspects). The second Regulation on corresponding adjustments will be analyzed in a forthcoming article.Continue Reading

By Ahmed Jooma (Independent Tax, Legal, and Public Policy Consultant)

On February 21, 2018, South Africa’s Finance Minister, Malusi Gigaba, presented the country’s National Budget, which will be tougher on the populace than on multinational corporations. Most of the tax changes that will affect cross-border transactions are of a technical nature. A continued focus on base erosion and profit shifting is expected to assist in arresting the deteriorating fiscal environment. This is further exacerbated by pressure to maintain a relatively low corporate tax rate in the face of tax competition.
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Chartered Accountants Australia and New Zealand (CA-ANZ) has stressed that by implementing the Taxation (Neutralising Base Erosion and Profit Shifting) Bill in its current form, the New Zealand Government would be “going further than most other OECD countries.”Continue Reading

KPMG UK has announced the appointment of Sarah Churton to its international tax practice.Continue Reading

By Jian-Cheng Ku (Legal Director, DLA Piper Nederland N.V.) and Jeroen Swart, (Tax Adviser, DLA Piper Nederland N.V.)

On February 18, 2018, the Dutch State Secretary of Finance announced that it will revise the Dutch tax ruling practice in light of results from a review conducted to examine if Dutch tax rulings met Dutch procedural requirements. Over 4,000 Dutch tax rulings were reviewed.

Current practice and review

A tax ruling provides Dutch taxpayers with the opportunity to obtain advance certainty on the tax consequences of proposed legal transactions. Taxpayers and the tax authorities are able to avoid potential disputes through tax rulings, which provide upfront assurance. The Dutch tax ruling practice is considered an important pillar of the Dutch business climate.Continue Reading

On February 19, 2018, India gazetted a revised tax treaty with Kenya. The revised treaty was signed by both countries in July 2016.Continue Reading

Japan and Spain have agreed in principle to the text of a new tax treaty.

The new tax treaty will replace the existing treaty between both countries, which entered into force in 1974.Continue Reading

Serbia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading

By  Bram Markey (Director, Transfer Pricing, PwC Belgium)

The Belgian tax authorities are increasing their manpower, shifting focus areas, and stepping up national and international cooperation with other tax authorities, with a clear view to audit transfer pricing and other international tax matters in a more targeted and efficient way, writes Bram Markey, Director, Transfer Pricing at PwC Belgium. Continue Reading

India on February 17 signed a tax treaty with Iran. The treaty is similar to the ones entered into by India with other countries.Continue Reading

By Alex Cooper

The New Zealand Inland Revenue is seeking to rectify a drafting error in a new rule to limit the rate of deductible interest on related-party, cross-border debt (the restricted transfer pricing rule) in the Taxation (Neutralising Base Erosion and Profit Shifting) Bill.Continue Reading

Global Tax Management, Inc., leading US corporate tax services firm, has added transfer pricing specialist Kevin Croy to the firm’s international tax practice.Continue Reading

Ireland and Ghana signed a new tax treaty on February 7, 2018. The procedures to ratify the treaty are underway.

Ireland is also negotiating and renegotiating existing treaties with foreign jurisdictions.

 According to the tax authority, Ireland’s existing treaty base will also be updated to incorporate provisions set out in the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.

By Aurelio Massimiano (Partner, Maisto e Associati) and Matteo Cataldi (Associate, Maisto e Associati)

On December 29, 2017, the Italian Government published Law No. 205 of December 27, 2017 (Budget Law) in the Italian Official Journal, which contains key tax measures including a new tax on digital transactions (Web Tax) and revisions to the definition of permanent establishment (PE) in the domestic law.Continue Reading

By Terence WILHELM (Attorney at Law, Managing Partner, CARA Avocats, France) 

On December 31, 2017, the French Government gazetted Finance Act, 2018, which revises the current transfer pricing documentation requirements in France. Accordingly, companies falling within the ambit of the new requirements will need to newly submit to the tax authority a two-fold documentation comprising “master” and “local” files, developed under Action 13 of the OECD’s base erosion and profit shifting (BEPS) project. The revised transfer pricing documentation requirement is inserted in Article L13AA of the French Procedural Tax Book (Livre des procedures fiscales) and is applicable to fiscal years beginning January 1, 2018.
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By Alex Cooper

US Congressman David Valadao has urged Treasury Secretary Steven Mnuchin to renegotiate the US tax treaty with Armenia with a view to ending double taxation currently imposed on businesses in both countries.Continue Reading

By Alex Cooper

On February 2, 2018, the Cayman Islands’ Ministry of Financial Services issued an Industry Advisory on the Islands’ country-by-country (CbC) reporting notification requirements.Continue Reading

International law firm Hogan Lovells has hired Tom McFarlane as head of transfer pricing (EMEA) for the firm’s growing transfer pricing practice. He will be working from the firm’s London office.Continue Reading

By Alex Cooper

On February 7, 2018, the Indian Government approved the signing and ratification of a protocol to amend the country’s tax treaty with China.Continue Reading

By Alex Cooper

On February 5, 2018, the UAE President issued a federal decree ratifying the country’s tax treaty with Paraguay.Continue Reading

Global law firm Morgan Lewis has added to its Chicago tax team Joshua Richardson, Adam Beckerink, and Michael Liu, who will assist the firm’s clients operating in the aftermath of historic changes in the US tax laws.Continue Reading

On February 7, 2018, the Indian tax authority announced that it entered into two bilateral advance pricing agreements (APAs) in the month of January 2018.Continue Reading

On January 31, 2018, Bermuda’s Finance Ministry released an updated list of tax jurisdictions that will be treated as “reportable jurisdictions” for the purposes of the country-by-country (CbC) reporting standard for the 2016 and 2017 reporting periods.Continue Reading

The Australian Taxation Office (ATO) has reminded significant global entities to file, by February 15, 2018, their country-by-country (CbC) reporting statements for the year ending December 31, 2016.Continue Reading

Italy and Colombia have signed a new tax treaty in line with the base erosion and profit shifting (BEPS) project.Continue Reading

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)

The Indian Government has, in recent past, taken bold and practical measures to align the Indian transfer pricing regulations with global best practices by introducing country-by-country reporting and “master” file regulations; interest limitation provisions; revising the rates under the safe harbor rules; rationalizing specified domestic transactions; and introduction of range concept and use of multiple-year data. Additionally, the Government has made several attempts on the administrative side to reduce litigation and introduce a taxpayer-friendly regime. Having said that, there are certain ambiguities that need to be resolved.

In the 2018 Budget, which is due to be presented on February 1, 2018, we hope to see appropriate steps being taken to address these ambiguities, some of which are listed below.Continue Reading

By Josh Bamfo (Partner & Head, Transfer Pricing Services, Andersen Tax, Nigeria)

Since the signing of the Multilateral Competent Authority Agreement by the Federal Inland Revenue Service (FIRS) and its subsequent ratification by the Federal Executive Council in 2016, most Nigerian taxpayers and tax practitioners have been keenly waiting for the implementation of a country-by-country (CbC) reporting requirement, developed under Action 13 of the base erosion and profit shifting (BEPS) project. Nonetheless, we were still surprised by the FIRS’ communication via its official Twitter handle on 24 January, 2018, that the Income Tax (Country-by-Country Reporting) Regulations, 2018, (CbC Regulations) has now been signed by the Federal Government of Nigeria, and will be gazetted soon.Continue Reading

Senior officials from Greece and Bulgaria met on January 18, 2018, to discuss ways to tackle base erosion and profit shifting by certain Greek businesses, who transfer their headquarters to Bulgaria to benefit from a low corporate tax rate in Bulgaria.Continue Reading

Țuca Zbârcea & Asociații Tax SRL, an affiliate of Romanian law firm Țuca Zbârcea & Asociații, has hired transfer pricing specialist Andreea Florian to strengthen its tax advisory practice.Continue Reading

On January 11, 2018, international law firm DLA Piper announced that it has appointed Jessica Tien as a principal economist in Silicon Valley.Continue Reading

On January 15, 2018, the Government of Hong Kong announced that it has entered into a bilateral arrangement with France to automatically exchange country-by-country (CbC) reports filed by multinational corporations.Continue Reading

On January 17, 2018, multinational law firm DLA Piper announced the appointment of Federico Pacelli as a partner in its international tax practice based in Italy. Federico will be leading the firm’s Italian transfer pricing team.

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KPMG India to newly appoint Hitesh Gajaria as Head of Tax from April 2018. Gajaria will succeed Girish Vanvari.

A revised tax treaty between Singapore and Sri Lanka entered into force on December 31, 2017.  Continue Reading

The new tax treaty between Ireland and Kazakhstan became effective on January 1, 2018. 

The tax treaty, which was signed by both countries in April 2017, entered into force on December 29, 2017.

Maltese Finance Minister, Edward Scicluna, has stressed that the country’s international tax regime is in line with the OECD’s BEPS proposals.Continue Reading

In a major expansion drive, Dutch law firm Houthoff has welcomed Paulus Merks as a new partner in the tax team.Continue Reading

Indian IT giant Infosys Limited has announced the successful conclusion of an advance pricing agreement (APA) with the US Internal Revenue Service (IRS), a move that will enhance predictability of the company’s tax obligations in respect of its US operations.Continue Reading

Mongolia has joined the OECD’s Inclusive Framework on BEPS, bringing the total number of countries participating in the project on an equal footing to 111.

Members of the framework work together with other OECD and G-20 countries on implementing the BEPS package consistently and on developing further standards to address BEPS issues.

The Irish Tax and Customs is has opened the filing facility for the receipt of country-by-country (CbC) reports for fiscal years ending in 2016.Continue Reading