International tax news
Switzerland to exchange financial account information with 33 more countries for tax purposesAugust 15, 2019 Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . . OECD releases “stage 2” reports on tax dispute resolution in US, UK, Belgium, Switzerland, Canada, NetherlandsAugust 14, 2019 The OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... on August 13 published six “stage 2” peer review reports assessing whether the United States, United Kingdom, . . . Israeli tax authorities issue updated transfer pricing declaration Form 1385August 12, 2019 The Israeli tax authorities recently issued an updated Form 1385, which is a declaration regarding intercompany transactionsIntra-Group Transactions are interactions between entities within the same multinational enterprise (MNE). Such transactions form the backbone of related-party dealings and are essential in managing global operations and aligning business objectives across jurisdictions. Understanding intra-group transactions is critical in international tax and transfer pricing, as they directly impact a company's tax obligations, profitability, and compliance standing. Tax professionals, accountants, lawyers,... with related parties, write Jacky Houlie, JH & Co. Law Office and Shlomo Hubscher JH Consulting Ltd . . . |
IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangementsAugust 5, 2019 The US IRS will once again examine allocations between group members of employee . . . The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?August 2, 2019 Statistics published earlier this week by the European Commission on member state advance pricing agreement (APAAdvance Pricing Agreements (APAs) have emerged as a critical tool for managing transfer pricing challenges. APAs are formal agreements between a taxpayer—often a multinational enterprise (MNE)—and one or more tax authorities that pre-determine the appropriate transfer pricing methodology for specified intercompany transactions over a set period, typically up to five years, with the possibility of renewal. The primary purpose of...) and mutual agreement procedure (MAP) programs suggest that the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve.../G20 base erosion profit shiftingProfit Shifting is a strategic practice employed by multinational enterprises (MNEs) to reduce their global tax liability by shifting profits from high-tax jurisdictions to low- or no-tax jurisdictions. The primary method involves transferring income-generating activities, intangible assets, or other high-value components within the group to countries with favourable tax regimes. Profit Shifting is a critical concern for tax authorities and... project has increased the scope for differences of opinion between tax authorities of different countries, writes Danny Beeton of Arendt & Medernach, Luxembourg . . . UAE country-by-country reporting rules publishedJuly 30, 2019 Saumitra R. Bhagwat and George German of Deloitte Middle East discuss new UAE Ministry of Finance transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... guidance which sets out country-by-country reporting compliance obligations for multinational corporation groups. . . |
| Finland budget offsets personal income tax reduction with hikes on fossil fuel, alcohol, tobacco: Aleksi Teivainen / Helsinki Times→August 14, 2019 US and Curacao negotiating country-by-country reporting exchange agreementAugust 14, 2019 The United States and Curacao are negotiating an agreement . . . Proposed IRS regs address cloud computing transactions, copyrighted article downloadsAugust 13, 2019 The US IRS on August 9 issued proposed regulations (REG-130700-14) concerning the income taxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and welfare programs. The tax is generally calculated as a percentage of the taxable... . . . Armenia, Kyrgyzstan sign tax treaty: ARMENPRESS→August 12, 2019 Uber generated USD 6.1 b Dutch tax deduction by transferring IP with increased value from a Bermuda sub to Dutch sub controlled by Singapore company: Lynnley Browning & Eric Newcomer / Bloomberg→August 12, 2019 CIAT database reflects progress made by 15 countries implementing BEPS recommendationsAugust 9, 2019 In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . . Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLIAugust 9, 2019 The Australian government on August 9 published the synthesized texts of . . . BEPS multilateral tax treaty to enter into force for Ukraine August 8, 2019 Ukraine today deposited with the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... legal documents ratifying . . . Albania joins Inclusive Framework on BEPS to address multinational tax issuesAugust 8, 2019 The OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... today announced that Albania . . . |
| Denmark must adopt EU controlled foreign company tax rules, Commission saysJuly 30, 2019 The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . . EU Commission says Greece must allow deductions for foreign lossesJuly 30, 2019 The EU Commission has charged that Greece’s tax treatment of losses incurred . . Industry group to file complaint with EU Commission alleging French digital tax is illegal State aid: Isabel Gottlieb / Bloomberg Tax→July 30, 2019 |
WORTH READINGs
Lucas de Lima Carvalho
“GLOBE and the Supranational ‘Nudges’ Affecting Domestic Tax Policy”
Tax Notes International, Tax Analysts, July 29, 2019 (subscription service)
Leopoldo Parada
“How the Vodafone Magyarország Opinion Affects EU Debate on Turnover-Based Digital Taxes”
Tax Notes International, Tax Analysts, July 29, 2019 (subscription service)
