Int'l Tax News

Posted on

Treasurys plan to fix to US debt-equity tax regs falls short, GOP lawmakers say

  • By Multinational Tax & Transfer Pricing News
by Multinational Tax & Transfer Pricing News
US Treasury's plan to revise six problematic areas in the proposed section 385 debt-equity regulations does not go far enough to allay concerns about regs' negative impact on the US economy, Republican lawmakers said today in a letter to Treasury Secretary Jacob Lew.
To read more go here

Posted on

Asia Pacific nations slashing corporate taxes in competative war

International Tax Review

by Anjana Hines

Indonesia may have started Asia's 'race to the bottom' on corporate tax as it looks to match Singapore and stop companies from keeping assets offshore. Others are announcing cuts to stay in the race. @

To read more go here

Posted on

New Zealand charges GST on e-commerce

International Tax Review

Foreign businesses offering digital services should prepare themselves for more e-commerce taxes and more rules from New Zealand. @

To read more go here

Posted on

Russia's VAT on digital service creates short timeframe for compliance

International Tax Review

by Joe Stanley-Smith

Businesses have just five months to prepare for Russia's new VAT rules that impose a tax on e-services from 2017. @

To read more go here

Posted on

OECD draft tackles multinational corporation tax avoidance though payments to branches

  • By Multinational Tax & Transfer Pricing News
by Multinational Tax & Transfer Pricing News
The OECD today released a draft report for countries that seek to improve their laws to counteract tax avoidance by multinationals through "branch mismatch structures."
To read more go here

Posted on

Public comments received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines

  • By OECD.org
by OECD.org
On 4 July 2016, interested partieswere invited to review the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings". The OECD is grateful to the commentators for their input and now publishes the comments received.
To read more go here

Posted on

Public comments received on the discussion draft on the design and operation of the group ratio rule under BEPS Action 4

  • By OECD

by OECD

On 11 July 2016, interested partieswere invited to provide comments on a discussion draftwhich dealswith elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.@

To read more go here

Posted on

Multilateral Convention for tax co-operation breaks through the 100 mark

by Grace Perez-Navarro (OECD.org)

In a ceremony at OECD Headquarters in Paris today, Burkina Faso, Malaysia, Saint Kitts and Nevis, Saint Vincent and the Grenadines, and Samoa signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, bringing the number of participating jurisdictions to 103.@

To read more go here

Posted on

PE risk of cross-boarder service to China

International Tax Review

by Maggie Zhuang

Foreign businesses offering cross-border service provisions to Chinese entities must take caution as the tax authorities are becoming more confident than ever in looking into cross-border transactions involving Chinese companies. @

To read more go here

Posted on

OECD Interest Deduction Rule May Spur Different Approaches

by Alex M. Parker
New OECD rules to limit excessive interest deductions might be interpreted differently in different countries, increasing compliance costs for taxpayers, according to several law and accounting firms, aswell as other business associations.
The concernswere raised in comments to the Organization for Economic Cooperation and Development,which issued a draft of suggested legislation on a "group ratio rule" for countries to use as away to limit interest deductions based on intercompany debt.
To read more go here Subscription Required

Posted on

Ireland, U.S. to Renegotiate Tax Treaty

The U.S. and Ireland are renegotiating their 1997 income tax treaty,whichwas amended by a protocol in 1999.
"Discussions have begun"with the U.S. Treasury Department "on updating certain elements" of the double tax treaty, the Irish Finance Department said in an Aug. 25 announcement.
To read more go here Subscription Required

Posted on

Puerto Rico's Wal-Mart' Tax Invalid, Appeals Court Holds

by Doloresw. Gregory
Puerto Rico's alternative minimum tax is unconstitutional on its face, a federal appeals court ruled, affirming a lower court's injunction that bars enforcement of the tax againstwal-Mart Puerto Rico Inc. (Wal-Mart P.R., Inc. v. Zaragoza-Gomez, 1st Cir., No. 16-01370, 8/24/16).
The U.S. Court of Appeals for the First Circuit said Aug. 24 that it is "indisputable" that the AMT unfairly targets cross-border transactions.
To read more go here Subscription Required

Posted on

OECD releases discussion draft on branch mismatch structures

  • By PwC
by PwC
On 22 August 2016 the OECD published, for discussion, recommendations for domestic laws thatwould neutralise the effect of payments involving certain branch mismatch arrangements.
This expansion of the final Base Erosion and Profit Shifting (BEPS) Action 2 paper, Neutralising the Effects of Hybrid Mismatch Arrangements, issued on 5 October 2015, adds even more complexity to that very long and complicated hybrid mismatch guidance.
To read more go here

Posted on

Debt-Equity Rules Big Concern for ABA Tax Section: New Chair

Action on the controversial rules to curb multinational companies from stripping income out of the U.S. through loans to subsidiaries remains one of the highest priorities of the American Bar Association Section of Taxation, its incoming chair told Bloomberg BNA.
To read more go here Subscription Required

Posted on

Republicans Keep Up Pressure on Debt-Equity Regulations

by Kaustuv Basu
Seven Republican senators are questioningwhether the Treasury Department is taking into account lawmakers' concerns about controversial debt-equity regulations.
To read more go here Subscription Required

Posted on

U.S. Treasury Ups Pressure on EU Over Apple, Other Inquiries

  • By Saleha Mohson
The U.S. is stepping up its effort to convince the European Commission to refrain from hitting Apple Inc. and other companieswith a demand for possibly billions of euros in underpaid taxes.
In awhite paper released Aug. 24, the Treasury Department said the Brussels-based commission is taking on the role of a "supra-national tax authority."
To read more go here Subscription Required

Posted on

Treasury: EU State Aid Investigations Undermine BEPS Project

by Ryan Finley
By creating a unique interpretation of the arm's-length principle that strays from the OECD transfer pricing guidelineswithout offering any coherent guidance as to how itwill be applied, the European Commission may threaten the consensus achieved through years of negotiation during the base erosion and profit-shifting project, according to a Treasurywhite paper.
To read more go here Subscription Required

Posted on

GOP Taxwriters Ask Lew to Explain His Role in Debt-Equity Regs

by Kat Lucero
Seven Senate Finance Committee Republicans are demanding that Treasury Secretary Jacob Lew explain his role duringwhat may seem to be the final stretch in approving the controversial proposed debt-equity regs.
To read more go here Subscription Required

Posted on

Proposed Section 385 Regulations Go Way Too Far

James J. Tobin of Ernst & Young examines documentation and information reporting standards and "per se stock" rules proposed under earnings-stripping regulations (REG-108060-15).
To read more go here Subscription Required

Posted on

Rewrite Earnings-Stripping Rules, GOP Tax-Writers Tell Lew

by Kaustuv Basu
Top Republican tax-writers in Congress are urging the Treasury Department to completely overhaul or repropose regulations that seek to curb corporate earnings stripping.
To read more go here Subscription Required

Posted on

Hatch, Brady Renew Effort to Stop Treasury's Debt-Equity Regs

by Dylan F. Moroses, Kat Lucero & Stephen K. Cooper
House and Senate taxwriters August 22 renewed their effort to derail Treasury's proposed debt-equity regulations, sending two letters urging the department to revise its rules or face legislative action.
To read more go here Subscription Required

Posted on

OECD Discussion Draft Targets Branch Hybrid Mismatches

by Alex M. Parker
Countries may soon have new blueprints for how to nix tax exemptions for companies that use branches to create so-called hybrid mismatch arrangements after the OECD's latest discussion draft of legislative recommendations.
To read more go here Subscription Required

Posted on

OECD Releases Discussion Draft on Branch Mismatch Structures (1)

by Alexander Lewis
The OECD has released a public discussion draft that recommends improvements to domestic laws to dealwith several of the most common types of branch mismatch structures.
To read more go here Subscription Required

Posted on

Profit Split Should Be the Default Method, BEPS Group Says

by Ryan Finley
A simplified version of the profit-split method should be considered the best transfer pricing method unless the taxpayer can establish that a one-sided method is clearly more appropriate, according to a network of tax experts, nongovernmental organizations, and tax justice campaigners.
To read more go here Subscription Required

Posted on

News Analysis: The European Union's Vanishing Withholding Tax Regimes

by Ajay Gupta
In a move toward implementing action 14 2015wTD 193-31: Consultation Documents and Responses of the OECD's base erosion and profit-shifting project, Brazil's Federal Revenue Department (FRD) on August 19 issued a consultation document on rules for mutual agreement procedure (MAP) cases for disputes involving tax treaties.
To read more go here Subscription Required

Posted on

Transfer Pricing Officer Can't Use Entity-Level Reports, Mumbai Tribunal Rules

by Sherry Samuel Oommen
The transfer pricing officer (TPO) cannot adopt entity-level reports for benchmarking an international transaction if the taxpayer furnished segmental reports, the Mumbai Tribunal held in Paradigm Geophysical India Private Ltd. (IT Appeal No. 1878 (Mum.) of 2014), made public August 19.
To read more go here Subscription Required

Posted on

Brazilian tax authorities issue proposed ruling on the definition of 'significant economic activities' for purposes of 'gray list'

  • By PwC
by PwC
The Brazilian tax authorities on May 30, 2016, issued proposed ruling PC 007/2016, stating their view of the intended meaning of 'significant economic activities' for purposes of Article 2 of Normative Instruction 1,037/2010 (NI 1,037/2010).
NI 1,037/2010 names blacklisted countries and privileged tax regimes ('gray list') from a Brazilian tax perspective.
To read more go here

Posted on

News Analysis: Tax Transparency Is in the Eye of the Beholder

Mindy Herzfeld examines recent unsuccessful efforts by nongovernmental organizations to persuade the OECD and the IRS to require multinationals to make their country-by-country reports public and discusses the next battlegrounds for the fight to increase tax transparency: the SEC and the Financial Accounting Standards Board.

To read more go here Subscription Required

Posted on

Unprecedented ruling in Brazil boosts PIS and Cofins credits for businesses

The Federal Administrative Court of Appeals (CARF) has issued an unprecedented ruling, by majority vote, on PIS and Cofins credits related to the acquisition of inputs for commercial companies.

To read more go here Subscription Required

Posted on

Russia's VAT on digital services creates short timeframe for compliance

Businesses have just five months to prepare for Russia's new VAT rules that impose a tax on e-services from 2017.

To read more go here

Posted on

Republicans Take New Tack on Taxing Companies Overseas Profits

President Ronald Reagan once chided government's approach to the economy as following this mantra: "If it moves, tax it."

Today's Republicans are following Mr. Reagan's ideas by trying the exact opposite approach. The tax plans from House Republicans and presidential candidate Donald Trump stop aiming at the moving target of U.S. companies' foreign profits.

Their planswould alter existing rules so thoroughly that companieswould get little advantage from cross-border tax maneuvers they perfected over decades and move the U.S. toward taxing immobile parts of the economy.

To read more go here

Posted on

OECD releases discussion draft on branch mismatch structures under Action 2 of the BEPS Action Plan

  • By OECD

Interested parties are invited to provide comments on a discussion draftwhich dealswith branch mismatch structures under Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.

To read more go here

Posted on

Corporate Income Tax Rates around the World, 2016

It iswell known that the United States has the highest corporate income tax rate among the 35 industrialized nations of the Organisation for Economic Co-operation and Development (OECD). However, it is lesswell known how the United States stacks up against countries throughout the entireworld.

To read more go here

Posted on

Inversions Lawsuit Could Change Tax Regulation Landscape

by Alison Bennett
The first legal action against the Treasury's rules to stop companies from changing addresses to reduce U.S. tax bills is highlightingwhat may be a sharp turning point for tax regulations going forward.
To read more go here Subscription Required

Posted on

Australia: Offshore marketing hubs - ATO releases draft discussion paper

  • By PwC
by PwC
On August 10, 2016, the Australian Taxation Office (ATO) released for public comment a 29 page draft discussion paper (DP) that outlines the ATO compliance approach to transfer pricing issues related to centralized operating models or 'hubs'. The focus of the DP is offshore marketing hubs but the ATO plans to issue guidance in relation to other hubs.
To read more go here

Posted on

The Potential Tax Effects of Brexit on Investors and Taxpayers in Ireland

Bloomberg

by Louise Kelly and Geraldine McCann
The U.K.'s decision to leave the EUwill inevitably cause a period of great uncertainty for businesses and individuals,write Louise Kelly and Geraldine McCann of Deloitte Ireland. The authors look at potential tax implications for investors and taxpayers in Ireland, particularly for thosewhere there is a close business relationshipwith the U.K.
To read more go here Subscription Required

Posted on

Is China's VAT Reform Helping the Economy?

  • By East Asia Forum
by East Asia Forum (Economywatch)
As of 1 May 2016, China has fully replaced its business taxwith a value-added tax (VAT) across all industries in a bid to streamline tax structures and reduce the tax burden.
To read more go here

Posted on

Treasury Releases Letter on Debt-Equity Rules Under FOIA

  • By FOIA
The Treasury Department released one outgoing letter under provisions of the Freedom of Information Act, for theweek ending Aug. 14.
To read more go here Subscription Required

Posted on

Intangible-Shifting to Foreign Partners Slows: Practitioners

Deals intended to avoid paying tax on appreciated property by shifting the property to overseas partners have slowed since the IRS issued guidance last year denouncing the practice, tax professionals said.
To read more go here Subscription Required

Posted on

BEPS Through an Indian Prism

India, as a rapidly growing economic power and member of the G-20 and the OECD, has been assessing the Base Erosion and Profit Shifting Action Plan. Bhavik Timbadia and Ganesh Krishnamurthy of BMR & Associates explore the country's response in detail.
To read more go here Subscription Required

Posted on

Apples Tim Cook set to battle for corporate tax reform

by Jennifer Booton (Marketwatch)
Apple Inc. CEO Tim Cook believes U.S. corporate tax reform is imminent, and he's not afraid to flex his muscles as the leader of the nation's most valuable company to make sure it happens.
To read more go here

Posted on

Russia's VAT on digital service create short timeframe from compliance

International Tax Review

by Joe Stanley-Smith

Businesses have just five months to prepare for Russia's new VAT rules that impose a tax on e-services from 2017.

To read more go here

Posted on

Practitioners: Use Dry Runs' to Work Out Global Tax Reports

Bloomberg

by Alex M. Parker
Companies should prepare a "dry run" to help navigate occasionally ambiguous and unclear information requirements in global tax reports now required by the IRS, practitioners from previous hitPricewaterhouseCoopers LLP said.
To read more go here Subscription Required

Posted on

Tougher compliance rules proposed for New Zealand foreign trusts

International Tax Review

by Anjana Haines

New Zealand's government has confirmed that foreign trustswill have to disclose more information to the tax authorities as it gets tough on tax in thewake of the Panama Papers.@

To read more go here

Posted on

Lawsuit on IRS Inversion Rules May Be Fascinating' Battle

Bloomberg

by Alison Bennett
The first lawsuit filed against hotly criticized rules to block transactions that move corporations' tax homes overseas to cut U.S. tax bills may face an uphill climb, even as more companies say deals fell apart because of the regulations.
To read more go here Subscription Required

Posted on

A World Tax Court: The Solution to Tax Treaty Arbitration

by Jake Heyka
Jake Heyka examines tax treaty arbitration standardswhile demonstrating that as a matter of fundamental justice, arbitration should be revamped; he proposes the creation of aworld tax court.
To read more go here Subscription Required

Posted on

Administration Exceeds Its Power With New Inversion Regs

by Diana Furchtgott-Roth
In this column, Furchtgott-Roth discusses the lawsuit brought against the IRS by the U.S. Chamber of Commerce and the Texas Association of Business over the inversion regulations. She concludes that lowering corporate rates is the optimalway to prevent inversions.
To read more go here Subscription Required

Posted on

Potential tax implications of Brexit on industrial products and services companies

  • By PwC
by PwC
The implications of the UK public vote to leave the European Union (EU) for the UK, the EU, and the rest of theworld depend to a substantial extent on the agreedwithdrawal terms, aswell as negotiationswith other countries. There are many misconceptions about how the referendum vote impacts taxes, but it causes no major tax legislative changes directly. However, the market volatility thatwe have seen since the vote could affect some tax-related issues. In addition, tax policy changes may, in time, result fromwhat takes place. This insight covers some areas of uncertainty that may impact multinational companies (MNCs) as a result of Brexit.
To read more go here

Posted on

Crisis and Deferral: How World Events Influence Subpart F

by Lukewagner
In this article, Lukewagner explains how global events have influenced the evolution of the subpart F regime, and he makes recommendations for future deferral reform.
To read more go here Subscription Required

Posted on

News Analysis: Freedom Fries: The House Republicans' Cash Flow Tax

by Lee A. Sheppard
In news analysis, Lee A. Sheppard examines the House Republicans' cash flow tax plan.
To read more go here Subscription Required

Member Companies

Back to top