The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, “tax law applies to transactions governed by, and the nature and legal...more
The IRS has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the Mutual Agreement Procedures (MAP) and other provisions of US...more
CAYMAN ISLANDS AND US SIGN FATCA AGREEMENT -
The United States and the Cayman Islands have signed a so-called Model 1 intergovernmental agreement.
The IGA is the first step in bring the Cayman fund industry...more
The Dutch Ministry of Finance has released a new transfer pricing Decree that is already in effect.
The New Decree, announced in late November, supersedes two earlier Decrees, that of 30 March 2001 (IFZ 2001/295) and...more
In This Issue:
A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more
Recent legislative and case-law developments have clarified India’s position on a number of tax and transfer pricing issues. While many of these developments are intended to increase certainty for foreign investors, a number...more
Colombia has issued its list of tax havens – an act that will negatively impact the tax effects of doing business in Colombia from or through any of these tax haven jurisdictions.
The Tax Havens list was issued under...more
The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies.
New Provisions of French Law -
Provisions Already Adopted -
The Organisation for Economic Co-operation and Development (OECD) has issued a memorandum in connection with the planned overhaul of transfer pricing documentation rules under its action plan to address base erosion and...more
The OECD has issued the “White Paper on Transfer Pricing Documentation” outlining ideas for new global standards for the annual transfer pricing documentation exercise required by more than 60 countries. ...more
Hot on the heels of the Australian transfer pricing law changes of 2012, the latest round of Australia's transfer pricing law amendments, contained in the Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit...more
The Law on On the amendment of the Tax Code of Ukraine as to transfer pricing was adopted by Ukrainian Parliament on 4 July 2013. To become effective, it must be signed by the President (expected soon). The new transfer...more
..Budget 2013-14: Government Targets Multinationals to Recover from GFC
..Recent Anti-avoidance Cases in China
..SAT Interprets Capital Gains Provisiosn in...more
On Thursday, May 9, the Multistate Tax Commission (MTC) hosted an Executive Committee (Committee) meeting in Washington, D.C. The Committee discussed many items ranging from election of new officers to Committee updates to...more
In This Publication:
- General Information
- Investment Factors
- Intellectual Property
- Principal Forms of Business Entities
In this issue:
- Shearman & Sterling Secures Favorable Settlement of $807 Million IRS Claim Against Ambac Financial Group
- AIG Case Requires Economic Substance for Transactions Generating Foreign Tax Credits
In a petition recently filed in the U.S. Tax Court, a taxpayer has challenged the Internal Revenue Service (IRS) regulation that provides that the IRS can reallocate income between affiliates even when foreign law prohibits...more
The International Ruling Office (the Office) of the Agenzia delle Entrate (the Italian Revenue Agency) has finally released the second issue of the Bulletin, almost three years after the release of the first issue. ...more
India possesses a dynamic and growing economy—one its government portrays as business friendly—and actively encourages continued foreign direct investment. At the same time, aggressive transfer pricing enforcement, including...more
During the Multistate Tax Commission’s (MTC ) Winter Committee Meetings in St. Louis on March 5, 2013, the Income and Franchise Tax Uniformity Subcommittee (I/F Subcommittee) declined to move forward with a project that would...more
Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more
The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more
On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied.
The legislation will come...more
An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. In that case,...more
As transfer pricing examination and controversy continue to grow, it’s becoming increasingly common for a multinational enterprise group to have advance pricing agreements (APA) with more than two countries (typically...more