2015

The Irish government, long criticized by other European countries and the United States for its friendlytaxtreatment of multinational giants like Apple andGoogle, on Tuesday announced a move that seemed likely to further incense its critics.
Ireland,whose corporatetaxrate of 12.5 percent is already one of the lowest in the developedworld, said itwould cut that rate in half for a newtaxcategory -- one covering revenue pegged to companies' patents and other intellectual property.
For the New York Times story, go here.

Nathalie Bravo, Rita Julien, Jasmin Kollmann, Alicja Majdanska, and Laura Turcan of the Vienna University of Business and Economics summarize a recent discussion of tax treaties that took place during a conference held by the Institute for Austrian and International Tax Law.
For thewWTD report, go here. (subscription required)

Although developing countrieswelcomed the final OECD base erosion and profit-shifting project reports, they need the support of the international community, particularly the IMF,world Bank, OECD, and U.N., to increase their tax administration capacities, a Senegalese official said.
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U.S. regulations on country-by-country reporting, still on track to be released by the end of 2015,will closely follow the OECD'swork under action 13 of its base erosion and profit-shifting project, Robert Stack, Treasury deputy assistant secretary (international tax affairs), said during an October 13webcast sponsored by KPMG LLP.
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Another G-20 summit next month means another opportunity forworld leaders to complain that global companies pay too little in taxes. Right on cue, theOrganization for Economic Cooperation and Development(OECD) has released its final proposals for combatting "base erosion and profit shifting," or BEPS.
For thewall Street Journal story, go here.

Treasury Secretary Jack Lew said Friday that the Obama administrationwould implement new rules thatwould lead to sharing business's informationwith foreign governments.
Lew praised the final recommendations from an Organization for Economic Cooperation and Development project meant to battle offshore tax avoidance, saying therewas a "critical need to fix our tax rules to address erosion of our corporate tax base."
For The Hill story, go here.

As part of the U.K. government'swar on tax avoidance, taxpayers are now being obliged to pay tax in dispute before the true liability is finally resolved; Trevor Johnson takes a look at a recent court case inwhich the taxpayerswere required to hand back tax repayments made to them more than 10 years ago.
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OECD tax chief Pascal Saint-Amans dismisses critics' claims that the OECD's base erosion and profit-shifting project does not go far enough to include all developing countries at the negotiating table.
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Ajay Gupta considers how creditability requirements restrict source jurisdictions from passing on the tab of environmental levies to the U.S. treasury.
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Mindy Herzfeld reviews the information exchange framework in the final report on BEPS action 5 and explains how that frameworkwill require spontaneous, automatic exchanges of rulings that go far beyond the scope of the earlier draft -- including retroactive rulings -- allwithout notice to taxpayers.
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Disagreement remains between the United States and some of its OECD counterparts on a number of issues addressed in the final base erosion and profit-shifting reports, according to Robert Stack, Treasury deputy assistant secretary (international tax affairs).
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G-20 finance ministers on October 9 expressed full support for the OECD's "historic" base erosion and profit-shifting project and stressed the importance of implementing the project's final measures in their countries' domestic legislation as soon as possible.
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Itwas billed as the biggest change to global taxation in a lifetime.when G20 governments agreed to overhaul the tax rules for multinationals in 2013, itwas a response to an unprecedented public outcry against avoidance.

The details of the blueprint have just been published andwere metwith criticism from campaigners and some academicswho said the approach takenwas fundamentally inadequate.
For the Financial Times story, go here.

Theworld's leading finance ministers agreed on Friday to change the rules on taxing profits, andwarned multinational companies they could no longer use their size and international presence to dodge taxes.

Under the rules, companies such as Starbucks, Amazon and Googlewill find it harder to concentrate their profits in low-tax countries and tax havens ÔøΩ a shift that promises to raise up to $250bn a year in extra tax revenues, according to the OECD.

For the Financial Times article, go here.

G20 finance ministers endorsed the final package of measures for a comprehensive, coherent and co-ordinated reform of the international tax rules during a meeting on 8 October, in Lima, Peru.
For the OECD release, go here.

On October 8, the G20 finance ministers met to discuss international tax rules. The Organization for Economic Cooperation and Development (OECD) has presented a series of measures to be considered.
For the SBE Council report, go here.

Developing countries are getting serious about increasing tax revenue as part of their domestic resource mobilization efforts, and theworld Bank and IMF are encouraged that they are taking advantage of "intensive technical support" to help strengthen their tax systems,world Bank President Jim Yong Kim said.
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Finance ministers of the Commonwealth announced that they have agreed to create aworking group on tax in a bid to increase their member states' participation and influence in international tax policy decision-making.
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After two years of breakneckwork, the Organisation for Economic Co-operation and Development (OECD) published its final reports lastweek on the Base Erosion and Profit Shifting (BEPS) project,which is aimed at coordinating international taxation among member countries.while thiswork may have drawn little attention from the general public, tax experts around the country are busy analyzing the impact of the recommendations,which are likely to be significant for many U.S.-headquartered companiesÔøΩincluding tech companies.
For the ITIC report, go here.

The G20 finance ministers on October 8 endorsed the final package of recommendations presented to them in Lima, Peru by the OECD, marking the end of the Paris-based organisation's project to tackle base erosion and profit shifting (BEPS). National authorities are now beginning to react.
For the ITR story, go here.

Michael Noonan, Irish finance minister, delivered his Budget 2016 speech on Tuesday. Taxpayers around theworldwere keen to see how the country amended its international tax provisions in thewake of OECD recommendations in this area.
For the ITR story, go here.

The OECD's final base erosion and profit-shifting reports do not fundamentally depart from the prior OECD guidelines or the section 482 regulations, according to Brian Jenn, attorney-adviser, Treasury Office of International Tax Counsel.
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The Canadian Department of Financewon't move quickly in considering the recommended best practices for limiting interest deductions under the final report on Action 4 of the international project to combat base erosion and profit shifting, a former government official said.
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The U.S. is "just not in a position to commit" to the OECD's common reporting standard in 2017 or 2018when early-adopting countries start taking part in automatic exchange of a broad range of financial information, a Treasury official said.
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Although the United States supports the best practices outlined in the OECD's final base erosion and profit-shifting report on action 14 (improving dispute resolution mechanisms), an IRS official expressed disappointment that many of those best practiceswere not included as elements in the minimum standard.
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In news analysis, Lee A. Sheppard reports on remarks made by the OECD's Pascal Saint-Amans during the Tillinghast lecture in New York, tying in Ireland's recent decision to reduce its tax rate for intellectual property developed in the country.
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Cyprus is one of Europe's premier business locationswith low, stable rates and favourable incentives offered to businesses. Recent tax developments have only served to make it more attractive.
For the ITR story, go here.

The European Commission approved a "technical update" to its controversial tax haven list, published earlier in 2015, but the changes don't exclude any of the listed 30 countries or independent territories considered tax compliant by the OECD.
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The number of countries that have agreed to mandatory binding arbitration in their bilateral tax treaties is likely to increaseÔøΩbut political support is key to that effort, according to Robert Stack, deputy assistant secretary for international tax affairs in Treasury's Office of Tax Policy.

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Despite beingwell intentioned, the carefully scrutinized bipartisan innovation box draft from Houseways and Means Committee members Charlesw. Boustany Jr., R-La., and Richard E. Neal, D-Mass.,will not achieve its desired objectives, a practitioner argued on October 13.
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In the first of a series of updates on intangibles valuation and intellectual property (IP) assets, Philip de Homont, principal at NERA Frankfurt, and Alexander Voegele, chairman of the firm's advisory board, look at issues related to multiple economic ownership of intangibles.
For the ITR story, go here.

A Karnataka High Court (KHC) ruling has re-interpreted Indian tax law relating to foreign tax credits, in a movewhichwill give more flexibility to taxpayers seeking to benefit from tax treaty provisions.
For the ITR story, go here.

Group-of-20 finance ministers approved measures to curb corporate tax avoidance that have been under debate for more than two years, as Germany's representative called for further steps to be taken and swift implementation.
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While new country-by-country reporting templates arising from the OECD's recent tax avoidance project have received the lion's share of attention, an accompanying requirement to produce a so-called master file may be causing more heartburn among large multinationals.
The requirement, to produce a global "overview" of a multinational entity's businessÔøΩincluding its supply chain, allocation of income and transfer pricing policiesÔøΩwill likely include very sensitive information about its operations, many practitioners said.
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The U.K. and the U.S. governmentswill adopt different approaches to implementing the OECD's final package of measures to tackle base erosion and profit shifting, panelists at a London forum said.

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The Department of Treasurywill likely not have to issue "substantial" changes to current transfer pricing regulations due to the OECD's Action Plan on Base Erosion and Profit Shifting, according to a senior official.

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Revised legislative proposals for a mandatory Common Consolidated Corporate Tax Base to be adopted throughout the European Unionwill include elements of profit shifting and tax abuse prevention, the European Commission said.
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Raffaele Russo, the head of the OECD base erosion and profit-shifting project, told participants at the International Bar Association annual meeting in Vienna on October 8 that he is proud of the number of countries that participated and that the BEPS reportswere completed on time for the G-20 meeting.
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Senior tax executives are expecting big changes to the global tax landscapeÔøΩand the enforcement outlookÔøΩas a result of the Organization for Economic Cooperation and Development's base erosion and profit shifting project, according to a new survey by EY LLP.
Many companies are already dealingwith legislation stemming from the BEPS process,while at the same time seeing a rise in tax audits related to BEPS areas, EY said in announcing the results Oct. 8.
For the DTR story, go here. (subscription required)

A top business lobby says itsworried that new international tax recommendations could put sensitive business information at risk.

The National Association of Manufacturers (NAM) said Thursday that the project from the Organization for Economic Cooperation and Developmentwould "impose substantial and unnecessary compliance costs on manufacturers."
For the Hill story, go here.

Development finance institutions are increasingly focusing on promoting responsible tax practices in their private sector investments, but there are limits towhat they can do to advance that agenda, according toworld Bank and Inter-American Development Bank officials.
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There is a global tax reset underway. Initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) projectwill fundamentally change the global tax landscape. Deloitte can help you navigate this new environment, delivering strategic insight and tax planning ideas.

For the Deloitte release, go here.

On 5 October 2015, the Organisation for Economic Co-operation and Development (OECD) released final reports on all 15 focus areas in its Action Plan on Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD described the next steps in itswork on BEPS, including additionalwork on technical matters and plans for monitoringwith respect to the implementation of the BEPS recommendations.
For the EY release go here.

On 5 October 2015, the Organisation for Economic Co-operation and Development (OECD) issued a final package of reports in connectionwith its Action Plan to address Base Erosion and Profit Shifting (BEPS), aswell as a plan for follow-upwork and a timetable for implementation. The OECD's BEPS Action Plan,whichwas launched in July of 2013 and endorsed by the G20, includes 15 key areas for identifying and curbing aggressive tax planning and practices and modernizing the international tax system. The OECD delivered interim reportswith respect to 7 of the 15 action items in September of 2014. Those 2014 reports have been consolidatedwith the remaining 2015 deliverables to produce a final set of recommendations for addressing BEPS.
For the KPMG NewsFlash, go here.

Australia's tax agencywill enter into discussionswith 80 multinational companies thatwould be "potentially affected" by a tax avoidance bill circulating in parliament,with hopes to persuade them to pay a greater share of taxes on profits generated in Australia.
For the DTR story, go here. (subscription required)

Temporary regulations to implement country-by-country reporting for 2016will be released by the end of the year, Michael McDonald, financial economist (business and international taxation), U.S. Treasury Office of Tax Analysis, said October 7.
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