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Irish FM Criticizes EU Demand For Apple Taxes

Jason Gorringe,, London // 17 August, 2017

Ireland's new Finance Minister, Paschal Donohoe, has described the EU's demand for the collection of up to EUR13bn (15.3bn) in "unpaid" taxes from Apple as unjustified, according to reports.
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UK Issues Guidance On Preparing CbC Reports

Jason Gorringe,, London // 16 August, 2017

The UK tax authority, HM Revenue and Customs, has issued guidance for businesses on the preparation of country-by-country reports in the required format.
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US IRS Now Accepting CbC Reports

Mike Godfrey,, Washington // 14 August, 2017

The US Internal Revenue Service has begun accepting country-by-country reports from multinational corporations.
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US Think Tank Says Earning Stripping Regs Should Be Retained

Mike Godfrey,, Washington // 09 August, 2017

Contrary to calls from businesses from the regulation's withdrawal, the Institute on Taxation and Economic Policy has called on the US Treasury to fully implement and strengthen its final Section 385 anti-earnings stripping debt-equity regulations, designed to reduce the benefits of corporate tax inversions.
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Ireland Explains Transfer Pricing Documentation Rules

Jason Gorringe,, London // 09 August, 2017

On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland's transfer pricing documentation requirements.
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Ireland Issues Guidance On Seeking MAP Assistance

Jason Gorringe,, London // 08 August, 2017

The Irish Revenue has published a new e-brief that explains the procedure through which taxpayers can request mutual agreement procedure assistance in Ireland, in cases where a company considers it has been subject to double tax.
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BEPS Toolkit Released On Offshore Indirect Transfers

Ulrika Lomas,, Brussels // 07 August, 2017

The Platform for Collaboration on Tax, a joint initiative of the OECD, the International Monetary Fund, the United Nations, and the World Bank Group, has launched for consultation a draft toolkit designed to help developing countries address concerns surrounding the tax treatment of offshore indirect transfers of assets.
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New Zealand To Proceed With BEPS Tax Changes

Mary Swire,, Hong Kong // 04 August, 2017

New Zealand's Finance Ministry has announced that it has decided on new measures to address base erosion and profit shifting.
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Bipartisan Support For Territorial US Tax System, BEPS Measures

Mike Godfrey,, Washington // 25 July, 2017

Orrin Hatch (R - UT) has said that members of Congress from both parties support replacing the US worldwide tax basis system for a territorial tax system.
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NZ Labour Would Introduce Diverted Profits Tax

Mary Swire,, Hong Kong // 18 July, 2017

New Zealand's leading opposition party has said it would introduce a diverted profits tax on multinational companies if elected.
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Google Wins EUR1.1bn French Back Tax Case

Ulrika Lomas,, Brussels // 14 July, 2017

An administrative court in Paris has ruled that Google is not liable for EUR1.1bn (USD1.25bn) in unpaid taxes, dealing a blow to the tax authority's anti-tax avoidance campaign against multinational companies.
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OECD Updates Transfer Pricing Guidelines

Ulrika Lomas,, Brussels // 14 July, 2017

On July 10, 2017, the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
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Cyprus Opens New Tax Amnesty For Past Tax Dues

Jason Gorringe,, London // 14 July, 2017

Cyprus's Tax Department has released details of a tax amnesty, which entered into force on July 3, 2017.
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Ireland Confident On FDI Prospects

Jason Gorringe,, London // 07 July, 2017

The Irish Government's inward investment agency has said that the country is continuing to attract foreign direct investment, and stressed that Ireland must remain competitive if it hopes to maintain its position of strength.
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ATO Says Compliance Rates High Among Larger Firms

Mary Swire,, Hong Kong // 06 July, 2017

The Australian Taxation Office estimates that the corporate tax gap for large businesses is around six percent, according to Commissioner Chris Jordan.
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MEPs Back Public CbC Reporting Proposals

Ulrika Lomas,, Brussels // 05 July, 2017

Members of the European Parliament have voted in favor of new EU country-by-country reporting requirements for multinationals with worldwide turnover of EUR750m (USD850.8m) or more.
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Australia Introduces Diverted Profits Tax

Mary Swire,, Hong Kong // 04 July, 2017

Australia's Diverted Profits Tax entered into force on July 1, 2017, under which multinationals found to have artificially shifted profits overseas will face a 40 percent tax on the diverted profits.
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Moscovici: CCCTB Is A Tool Against Tax Avoidance

Ulrika Lomas,, Brussels // 30 June, 2017

EU Tax Commissioner Pierre Moscovici has described the proposed common consolidated corporation tax base as a "decisive tool against corporate tax avoidance."
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IMF Urges Ireland To Adopt Cautious Fiscal Approach

Jason Gorringe,, London // 28 June, 2017

The International Monetary Fund has called on the Irish Government to broaden the tax base and build fiscal buffers from any higher-than-expected revenue receipts.
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OECD Issues Further Action 7, Action 8-10 BEPS Guidance

Ulrika Lomas,, Brussels // 27 June, 2017

The OECD has released for stakeholders' comments two new discussion drafts as part of its base erosion and profit shifting work.
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Think Tank: No Economic Reason For Irish Tax Cuts

Jason Gorringe,, London // 27 June, 2017

The Nevin Economic Research Institute has said that there is "no economic case" for the Irish Government to introduce tax cuts over the next three years.
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EU Presidency Confirms CbC Reporting Regime Changes

Jason Gorringe,, London // 26 June, 2017

The Maltese Presidency of the Council of the European Union has said that it has forwarded a proposal to amend the EU country-by-country reporting regime.
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Irish Opposition Concerned Over 'Vulnerable' CIT Base

Jason Gorringe,, London // 23 June, 2017

Irish opposition party Fianna Fail has raised concerns over the concentration of corporation tax receipts among a small number of multinational groups.
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Countries Urged To Sign Up To Mandatory Binding Arbitration

Ulrika Lomas,, Brussels // 19 June, 2017

The International Chamber of Commerce has stressed the need for more countries to adopt mandatory binding arbitration to better resolve double tax disputes.
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Google Not Liable For French Back Tax, Says Court Adviser

Ulrika Lomas,, Brussels // 16 June, 2017

An adviser to an administrative court in France has said that Google is not liable for EUR1.1bn (USD1.2bn) in back taxes because the company lacks sufficient presence in the country.
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EU Pressing Ahead With CbC Reporting Proposals

Ulrika Lomas,, Brussels // 27 June, 2017

The European Parliament's Economics and Legal Affairs committees have approved a measure that would require multinationals to make publicly available information about the tax they pay, on a country-by-country basis.
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Mauritius To Sign BEPS Convention By June 30

Lorys Charalambous,, Cyprus // 12 June, 2017

Mauritius will sign the OECD's Multilateral Convention to implement the tax treaty-related base erosion and profit shifting recommendations by the end of June 2017, the Finance Ministry has announced.
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ICC Warns Of Double Tax Risks Surrounding 'Substance' Tests

Mike Godfrey,, Washington // 12 June, 2017

The International Chamber of Commerce has called on governments to adopt uniform, predictable rules to determine the location of economic activity when applying new international tax rules centered on substance.
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68 Jurisdictions Sign BEPS Multilateral Instrument

Ulrika Lomas,, Brussels // 08 June, 2017

68 countries have signed the OECD's Multilateral Convention, designed to swiftly implement a series of tax treaty-related measures proposed in the OECD's base erosion and profit shifting project into these countries' double tax agreements.
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Switzerland Explains BEPS Changes To Treaty Network

Ulrika Lomas,, Brussels // 08 June, 2017

Switzerland has explained how it will amend its double tax agreements, after it signed the OECD's new multilateral tax compact to implement anti-base erosion and profit shifting measures.
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Enforcement Tax Yield From UK's Largest Firms Drops

Jason Gorringe,, London // 08 June, 2017

Investigations by HM Revenue and Customs into the corporate tax affairs of the UK's largest businesses yielded an extra GBP2.6bn (USD3.3bn) in revenue last year, according to figures obtained by international law firm Pinsent Masons.
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US, New Zealand Agree To Exchange CbC Reports

Mike Godfrey,, Washington // 07 June, 2017

The US Internal Revenue Service has signed a new bilateral arrangement with the New Zealand Inland Revenue to share country-by-country reports on an annual basis.
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Ireland Explains BEPS Changes To Its Tax Treaties

Lorys Charalambous,, Cyprus // 07 June, 2017

Ireland's Department of Finance has published a Technical Briefing Note, which sets out the country's proposed approach to the OECD Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.
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Revised Swiss VAT Rules To Enter Into Force In 2018

Ulrika Lomas,, Brussels // 05 June, 2017

Changes to Switzerland's Value Added Tax Act will enter into force on January 1, 2018, with the aim of removing VAT-related competitive disadvantages for domestic companies.
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Funds Industry Fears BEPS 'Substance' Changes

Jason Gorringe,, London // 05 June, 2017

Tax experts have highlighted the increasing importance of substance in the fund management sector in view of the OECD's base erosion and profit shifting project recommendations.
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Abu Dhabi Tax-Free Zone To Launch Foundations

Lorys Charalambous,, Cyprus // 02 June, 2017

Abu Dhabi Global Market, the low-tax international financial center, is seeking feedback on its proposal to allow the formation of "foundations," a trust-like entity widely used in civil law jurisdictions.
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Netherlands Consults On Dividend Tax Changes

Ulrika Lomas,, Brussels // 31 May, 2017

The Dutch Finance Ministry has opened an internet consultation on proposed changes to the Dutch dividend tax regime, which would expand the withholding tax exemption on distributions to shareholders in tax treaty countries.
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OECD Prepares For BEPS Action 6 Peer Reviews

Ulrika Lomas,, Brussels // 31 May, 2017

The OECD has released a document that will form the basis of the peer review and monitoring process of the base erosion and profit shifting Action 6 minimum standard.
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EU Council Adopts Directive On Hybrid Mismatches

Ulrika Lomas,, Brussels // 30 May, 2017

On May 29, 2017, the European Council formally adopted a new anti-avoidance directive, which aims at closing down hybrid mismatches between EU tax systems and those of non-EU countries.
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Russia To Sign OECD's BEPS Convention

Tatiana Smolenskaya,, Moscow // 30 May, 2017

Russia will sign the OECD's Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting, the Government announced on May 20.
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