International Tax News - December 2013

by DLA Piper


By Michael F. Patton

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 income tax treaties (or similar agreements) and the procedures applicable to Advance Pricing Agreements (APA).

The proposed revisions to the existing MAP and APA procedures intend, in part, to reflect the reorganization of the IRS MAP and APA programs into the Advance Pricing Mutual Agreement (APMA) Program, together with other IRS reorganizations that have resulted in a comprehensive, nationally coordinated IRS transfer pricing enforcement program.

The proposed revisions to the MAP procedures are generally a greater departure from current procedures than are the proposed changes to current APA procedures.

IRS has requested taxpayer comments on the proposed changes by March 20, 2014.

Find out more.


By Mark Burgess, Simon Gough, Paul Rutherford, David Thompson and Richard Woolich

UK Chancellor of the Exchequer George Osborne has released his Autumn Statement, the half-yearly update on the UK budget, which serves as a guide to the chancellor’s tax and spending plans.

Here we note highlights of the Statement that concern tax issues. Among the areas important for business are new anti-tax-avoidance measures and rules affecting equity finance, corporate losses, the bank levy rate and employee share ownership, as well as a new onshore allowance for shale gas extraction. Notably, the government remains committed to reducing the main UK corporation tax rate.

See the highlights here.


By Ágata Uceda

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. Other transfer pricing decrees are not modified by this new decree.

The new decree incorporates recent Dutch case law on transfer pricing, makes official certain points that were already being used in practice by the Dutch Tax Authorities during APAs or audits and includes interpretation of certain parts of the 2010 OECD Guidelines.

Find out more.


By Thomas S. Dick, Simon Airey, Jayne Newton, Aileen Barry and Rob Smith

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 into compliance with the US Foreign Account Tax Compliance Act (FATCA) and thus convey information about their US account holders to the IRS.

The signing of this IGA should be a welcome development for private investment fund sponsors that form Cayman entities to invest in US markets.

Find out more.


By Richard Woolich and Daan Arends

Important changes to the VAT place-of-supply rules affecting cross-border services will go into effect in the EU from January 1, 2015.

These changes will affect those businesses based both inside and outside the EU which are involved in the supply of telecommunication services, television and radio broadcasting services and e-commerce businesses (often called B2Cs) whose customers are consumers – for instance, private individuals or organizations that are not in business, such as certain charities and public bodies, which are not registered for VAT and make no business supplies.

What issues do affected businesses need to be taking into account ahead of this change?

Find out more.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© DLA Piper | Attorney Advertising

Written by:

DLA Piper

DLA Piper on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at:

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.